IRS Releases Final Forms 1094 and 1095 and Instructions for 2015

With the release of the final Forms 1094 and 1095 and accompanying instructions for 2015, the IRS has clarified the following important items regarding the reporting requirements under Health Care Reform:

• For a self-insured employer, almost any kind of group medical coverage will be considered minimum essential coverage (MEC), including grandfathered and non-grandfathered coverage.
• Minimal coverage, such as excepted benefits or dental- or vision-only coverage, does not constitute MEC.
• An employer sponsoring both a self-insured major medical plan and an HRA is required to report coverage under either the major medical plan or the HRA, but not both.
• An employer sponsoring both a fully insured major medical plan and an HRA for employees enrolled in the major medical plan is not required to report the coverage under the HRA for an individual covered by both arrangements.
• COBRA offers for terminated employees are not reported as offers of coverage under any circumstances, even if a former employee elects the coverage.

If you have questions about the reporting requirements, call ASR Health Benefits at (616) 957-1751 or (800) 968-2449.