What HRA sponsors need to know now about

6055 and 6056 ReportingEarly next year, employers offering a Health Reimbursement Arrangement that provides minimum essential coverage

(MEC) may be required to complete forms 1094-C/1095-C or 1094-B/1095-B. These forms are part of the new

§ 6055 and § 6056 reporting requirement, which was implemented by the IRS in an effort to ensure that employees

are either covered by a health plan that provides MEC or making an individual shared responsibility payment with

their income tax returns. Because the reporting will be on an individual employee basis, many employers are

concerned about how to determine which employees require reporting.

The good newsThe IRS has released guidance which indicates that as long as you put forth a “good faith effort” to file the report in

this first year, you will likely avoid any potential penalties.

MidAmerica is happy to assist you in this reporting process by first determining if you will need to report for any of

your employees and then pinpointing who those employees are. After the year-end, we will advise of any reporting

obligations you may have.

Which employees could be affected?The IRS guidance states that any employee enrolled in an HRA who does not have medical coverage through the

Employer sponsoring the HRA or through a government-sponsored program, such as Medicare, will need to be

reported. This includes individuals who may have medical coverage through another Employer or through their

spouse.

If the employee is enrolled in both an HRA and either a fully insured or self-insured medical plan sponsored by the

same employer, the HRA coverage will not need to be reported regardless of whether the HRA is directly integrated

with the employer’s health insurance. Therefore, employees participating in retiree HRAs and continuing on the

employer’s medical plan in retirement will not need to be reported, even though the HRA is not directly tied to the

employer’s health insurance.

If you offer an HRA to your active employees that limits their access until retirement or separation of service, you will

only need to report for those employees who have gained access to their funds, and only if the employee is not

enrolled in your medical plan.

Getting started - forms 1094-C/1095-C or 1094-B/1095-BYour first step is determining which category of employer you fall into.

w Applicable Large Employer (ALE) - 50 full-time employees, including full-time equivalent employeesw Small Employer - less than 50 full-time employees

If you are an ALEIf you are an ALE (for more information on how to determine your ALE status, click here) you will complete forms

1094-C and 1095-C. Under the Affordable Care Act’s employer shared responsibility provisions, if you are an ALE

you must offer minimum essential coverage to your employees (and their dependents) or make an employer shared

responsibility payment to the IRS. This responsibility is also sometimes referred to as the “pay or play provisions.”

If you are a small employerIf you have less than 50 employees, you will complete forms 1094-B and 1095-B.

https://www.irs.gov/Affordable-Care-Act/Employers/Determining-if-an-Employer-is-an-Applicable-Large-Employer

Next stepsYou can expect additional guidance and reporting details from us after the end of the calendar year. We are unable

to provide the information any sooner because the IRS requires that the reporting must include everyone who has

balances at the end of the calendar year 2015.

We will be tracking participants who do not have Employer sponsored health coverage, as well as those not yet

Medicare eligible. The IRS requires that census information for dependents also be reported; however, in this first

year of the reporting requirement you may understandably not have that information readily available. This is why the

IRS is recognizing any “good faith effort” to complete the report. Historically, MidAmerica has not collected dependent

information, but will provide any dependent information we currently have. In light of this new requirement, we are

implementing a new enrollment procedure to collect this data on a go-forward basis.

Our goal is to provide you with all necessary details, which includes your census and HRA balance information, well

in advance of the reporting due dates. This information will be uploaded to the plan sponsor website in a

downloadable excel file and will only be accessible by logging in. If you do not have a username and password for

MidAmerica.biz, please contact us at (800) 430-7999.

Important deadlinesFor calendar year 2015, your forms must be filed with the IRS by February 29, 2016 (if filing on paper) or March 31,

2016 (if filing electronically). If you have more than 250 returns, you are required to file electronically. You may request

an automatic 30-day extension by completing Form 8809, Application for Extension of Time to File Information

Returns.

Helpful linksw Form 1094-C

w Form 1095-C

w Instructions for Forms 1094-C and 1095-C

w Form 1094-B

w Form 1095-B

w Instructions for Forms 1094-B and 1095-B

Questions?

If you have questions, please email our Compliance Department at compliance@midamerica.biz.

The information provided is MidAmerica’s interpretation of the law and should not be considered legal guidance of any kind.

402 South Kentucky Avenue, Suite 500, Lakeland, FL 33801 n (800) 430-7999 n www.midamerica.biz

https://www.irs.gov/pub/irs-prior/i109495b--2015.pdfhttps://www.irs.gov/pub/irs-prior/f1095b--2015.pdfhttps://www.irs.gov/pub/irs-prior/f1094b--2015.pdfhttps://www.irs.gov/pub/irs-prior/i109495c--2015.pdfhttps://www.irs.gov/pub/irs-prior/f1095c--2015.pdfhttps://www.irs.gov/pub/irs-prior/f1094c--2015.pdf