On Sept. 5, 2013 the Internal Revenue Service (IRS) released the long awaited rules that describe the reporting that plans, employers and insurers will need to provide in support of the individual shared-responsibility and employer shared-responsibility requirements of the Patient Protection and Affordable Care Act (PPACA).  The rules are proposed, so some changes may occur when the rules are finalized.

Separate reporting will be needed with respect to providing minimum essential coverage (which affects both the individual shared-responsibility requirement/individual mandate and the “offer” part of the employer shared-responsibility/play or pay requirement) and offering affordable, minimum value coverage (which affects the “adequacy” part of the play or pay requirement and individuals’ eligibility for a premium subsidy.)  The reporting will occur with the same timing as W-2/W-3 reporting – the individual’s report will be first due Jan. 31, 2016 based on 2015 coverage and the employer “roll-up” report will be due by Feb. 28 (or March 31 if filed electronically).

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