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Employer Reporting Requirements

The Affordable Care Act (ACA) created a number of federal reporting requirements for employers and health plans. The additional reporting is intended to promote transparency with respect to health plan coverage and costs. It will also provide the government with information to administer other ACA mandates, such as the large employer shared responsibility penalty and the individual mandate.

ACA reporting requirements for employers and health plans:

  • Form W-2. ACA requires employers to report the aggregate cost of employer-sponsored group health plan coverage on their employees’ Forms W-2. The purpose is to provide information to employees regarding how much their health coverage costs. Employers that file fewer than 250 Forms W-2 are exempt from this reporting requirement until the IRS issues further guidance.
  • Large employer health coverage (Section 6056 – Forms 1094-C/1095-C). Large employers subject to ACA’s shared responsibility provisions must file a return with the IRS that reports the terms and conditions of the health care coverage provided to the employer’s full-time employees for the calendar year (1094-C). Related statements must also be provided to employees (1095-C).
  • Health coverage by health insurance issuers and sponsors of self-insured plans (Section 6055 – Forms 1094-B/1095-B). ACA requires every health insurance issuer, sponsor of a self-insured health plan, government agency that administers government-sponsored health insurance programs and any other entity that provides minimum essential coverage to file an annual return with the IRS reporting information for each individual who is provided with this coverage (1094-B). Related statements must also be provided to individuals (1095-B).
  • Transparency in coverage and cost sharing disclosures. ACA requires health insurance issuers seeking certification of a health plan as a qualified health plan (QHP) under an Exchange to disclose certain information to the Exchange, HHS and state insurance commissioner. QHP issuers must also make this information available to the public. The information subject to reporting includes claims payment policies and practices, data on enrollment and disenrollment, data on the number of claims denied, data on rating practices and information on cost-sharing and payments for any out-of-network coverage.
  • Quality of care. ACA requires group health plans and health insurance issuers to submit an annual report to the U.S. Department of Health and Human Services (HHS) regarding plan benefits and provider “reimbursement structures” that may affect the quality of care in certain ways. Grandfathered plans are not subject to ACA’s “quality of care” reporting requirement. The effective date of this requirement has not yet been determined.

The Wladis Companies, Inc. will continue to monitor health care reform developments and will provide updated information as it becomes available.