Code Section 6056 – What Information Must Be Reported?

The Affordable Care Act (ACA) created new reporting requirements under Internal Revenue Code (Code) Section 6056. These new reporting rules require applicable large employers subject to the ACA’s employer shared responsibility rules to report information on the health coverage offered to full-time employees to the Internal Revenue Service (IRS) and covered individuals. Related statements must also be provided to individuals.

Required Forms

The Section 6056 reporting will be accomplished using forms 1094-C and 1095-C. Each ALE is required to file the following forms with the IRS:

  • A single transmittal form (Form 1094-C) for all of the returns filed for a given calendar year; and
  • A separate employee statement (Form 1095-C) for each full-time employee.

On February 8, 2015, the IRS released final versions of Forms 1094-C and 1095-C (and related instructions). Note that these forms are for use in 2014. Reporting is not required for 2014, but reporting entities may voluntarily file these forms in 2015 for 2014 coverage. Reporting is first required in early 2016 for calendar year 2015. Forms and instructions for 2015 reporting have not yet been released and may contain some changes.

An ALE that maintains a self-insured plan must also report under Code Section 6055 as a provider of minimum essential coverage (MEC). Entities that are reporting under both Sections 6055 and 6056 will file using a combined reporting method, on Form 1094-C and Form 1095-C. The Form 1095-C has separate sections to allow ALEs that sponsor self-insured plans to combine reporting to satisfy both the Section 6055 and 6056 reporting requirements, as applicable, on a single return.

This Legislative Brief outlines the information required to be reported on Forms 1094-C and 1095-C under Code Section 6056. Please contact Horst Insurance if you need more information on Section 6056 reporting.

This article/Legislative Brief is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.


Code Section 6056 – What Information Must be Reported