CAB 14-4: The IRS has published two sets of final rules on the Affordable Care Act’s (ACA) information reporting requirements, providing guidance on the reporting of minimum essential coverage and of healthcare coverage. The minimum essential coverage reporting requirement under tax code section 6055 applies to employers that sponsor self-insured group health plans, group health insurance issuers, and the boards of trustees, association, or committees of multiemployer plans that provide minimum essential coverage. The healthcare coverage reporting requirement under section 6056 applies to large employers (with at least 50 full-time or equivalent workers) that are subject to the ACA’s employer “shared responsibility” (also known as “pay or play”) provisions. In general, the reporting entities must collect the information beginning Jan. 1, 2015, and include the information on a single, consolidated form submitted to the IRS and given to employees in 2016.

Separately, the Centers for Medicare and Medicaid Services (CMS) released a final rule governing insurance on the exchanges in 2015, but also providing guidance on the transitional risk reinsurance program (TRRP) fee that insurance issuers and self-funded plans must pay to help offset the costs of nongrandfathered individual coverage.