H&W: IRS Released Finalized Forms 1094 and 1095 “B & C”


The IRS has released Finalized Forms 1094 and 1095 “B & C” for 2014.  Forms 1094-B and 1095-B relate to the Individual Mandate (Section 6055) and forms 1094-C and 1095-C relate to Employer Shared Responsibility (Section 6056).

These are not required to be filed for 2014.

However, in preparation for the first required filing of these forms (that is, filing in 2016 for 2015), reporting entities may, if they wish, voluntarily file them.

Individual Mandate – Forms 1094/1095 “B”

Form 1095-B is used to report certain information to the IRS and to taxpayers about individuals who are covered by minimum essential coverage and therefore are not liable for the individual shared responsibility payment. Minimum essential coverage includes government-sponsored programs, eligible employer-sponsored plans, individual market plans, and miscellaneous coverage designated by Health & Human Services [HHS].

Every person that provides minimum essential coverage to an individual during a calendar year must file an information return and a transmittal. Most filers will use 1094-B (transmittal) and 1095-B (return). However, large employers (including government employers) subject to the employer shared responsibility provisions will report information about the coverage on 1095-C, Employer-Provided Health Insurance Offer and Coverage, instead of on Form 1095-B.

IRS Instructions for Forms 1094-B and 1095-B

Employer Shared Responsibility – Forms 1094/1095 “C”

Employers with 50 or more full-time employees (including full-time equivalent employees) use Forms 1094-C and 1095-C to report the information required under sections 6055 “AND” 6056 about offers of health coverage and enrollment in health coverage for their employees.

Form 1094-C (transmittal) must be used to report to the IRS summary information for each employer and to transmit Forms 1095-C (return) to the IRS. Form 1095-C is used to report information about each employee.

In addition, Forms 1094-C and 1095-C are used in determining whether an employer owes a payment under the employer shared responsibility provisions under section 4980H. Form 1095-C is also used in determining the eligibility of employees for the premium tax credit. Employers that offer employer-sponsored self-insured coverage also use Form 1095-C to report information to the IRS and to employees about individuals who have minimum essential coverage under the employer plan and therefore are not liable for the individual shared responsibility payment for the months that they are covered under the plan.”

IRS Instructions for Forms 1094-C and 1095-C


Additional Resource on Forms 1094 and 1095  from the IRS:  “Understanding Employer Reporting Requirements of Health Care Law

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