Section 6055: Which HRAs Must Report?

With the Affordable Care Act and the addition of section 6055 to the Internal Revenue Code, every provider of minimum essential coverage must now report their coverage information to the IRS, with reporting requirements beginning in 2016 for coverage year 2015.

It is worth noting that section 6055 reporting also applies to some health reimbursement arrangements (HRAs), specifically, those separate from the employer’s group medical plan. However, this reporting requirement does not apply to separate HRAs that reimburse for only dental or vision expenses. Thus, if your HRA is integrated with the group medical plan and/or reimburses for only dental or vision expenses, no section 6055 reporting is needed for the HRA.

On a side note, the IRS recently released draft versions of Forms 1094 and 1095, which are the forms necessary for section 6055 (and 6056) reporting. Note, these are drafts, so they may change by the final versions.

Section 6055 reporting

1094-B – www.irs.gov/pub/irs-dft/f1094b–dft.pdf

1095-B – www.irs.gov/pub/irs-dft/f1095b–dft.pdf

Section 6056 reporting

1094-C – www.irs.gov/pub/irs-dft/f1094c–dft.pdf

1095-C – www.irs.gov/pub/irs-dft/f1095c–dft.pdf