Draft Instructions for ACA Reporting Forms Issued

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Draft Instructions for ACA Reporting Forms Issued
Calendar02 September 2014

Late last week IRS issued draft instructions on ACA's play-or-pay and minimum essential coverage reporting explain how to detail data on the Forms 1094 and 1095 series and transmit these returns. Employers, insurers, and others will use these forms to report on individuals' plan eligibility and coverage, as well as employees' full-time status. Employers and other health coverage providers should review the instructions, along with the draft forms, to prepare for collecting 2015 data for the first reports due in early 2016. A 60-day comment period on the drafts is slated to begin Sept. 2. 

Following release of the draft instructions, IRS posted 6055 FAQs and 6056 FAQs summarizing these reporting obligations.

Last week also saw Pennsylvania — a key Republican-led state — gain federal approval to proceed with a compromise plan to expand its Medicaid program.

Looking ahead, CMS is expected to soon publish additional information intended to clear up confusion about how employers should proceed in applying for national health plan identifiers (HPIDs). Some employers are waiting for release of this guidance before applying for HPIDS. In the meantime, employers may want to identify two people who will serve as the sponsor’s “submitter” and “authorizing official” for the HPID application, and those individuals may want to register on the CMS Enterprise Portal. (One exception might be individuals associated with a sponsor having only fully insured health plans other than a health flexible spending account; that type of sponsor may possibly be excused from the HPID requirement.) 

Although Congress is in its final week of summer recess, a House subcommittee will convene in Indiana on Thursday to air concerns over how the law is affecting employers and health care costs.

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