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Employer Reporting Requirements; Collect Data Now for 2016

Feb 19, 2015

Even though we just started 2015, it’s time to start thinking about IRS 6055 and 6056 reporting requirements. True, mandatory compliance doesn’t begin until January 1, 2016 (for the 2015 reporting year). There are some things you should know and start doing now to prepare for compliance in 2016. 

Please note that reporting in 2015 for the 2014 plan year is voluntary. 

Let’s start with what fully insured and self-funded employers need to know now. If they haven’t already done so for purposes of the employer mandate, your clients must determine if they are an applicable large employer (ALE). The counting method is the same one used for the employer mandate: 

If your client employee count is hovering around 50 full-time employees and full-time equivalents, it is important to monitor their count monthly. 

The table below shows 6055 and 6056 reporting obligations by funding type/group size. 

Funding type/group size

6055 reporting (MEC) to IRS and covered employees

6056 (offer of coverage) to IRS

Solicitation for missing member SSNs

Self-funded ALE

Employer requirement

Employer requirement

Employer requirement


Fully insured ALE

Issuer requirement

Employer requirement

Issuer requirement

Self-funded small group

Employer requirement


Employer requirement

Fully insured small group

Issuer requirement

Issuer requirement

Issuer requirement

Next, here is what ALEs need to do in 2015 to be ready to report in 2016. 

Collect and document data

This includes but is not limited to:

  • Offer of coverage to employees and dependents, including the months that coverage was available
  • Names, SSNs and addresses for employees and dependents covered under the plan
  • Number of full-time employees for each month in the calendar year
  • Share of full-time employees’ monthly premiums broken out by calendar month (when applicable)


Determine and document how employees are counted

  • Useful if your client is audited by the IRS

Consider how you want to generate and deliver the required forms

  • Generate and deliver on your own or use a vendor
  • It may be more efficient for your client and their employees if you send the forms with the
    W-2 Form (not a requirement).


 To summarize, here are some key points to remember: 

For questions regarding anything above, please ​contact a member of your b&p Sales Team - 888.722.3373.

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