As part of the 6055/6056 reporting requirement you may be required to complete forms 1094-C/1095-C or 1094-B/1095-B for those employees with a Health Reimbursement Arrangement (HRA). It can be confusing to determine which employees will require the reporting and which ones will not. The good news is that the IRS says as long as you put forth a “good faith effort” in the first year to file the report, you will likely avoid any penalties. Whew!
The table below is quick resource for school, city and county employers to use to determine which individual employees you will need to report.
HRA benefits that must be included on 1094 and 1095 forms:
*Retiree-Only HRAs include HRAs where contributions are deposited during active employment or just following retirement. With a Retiree-Only HRA, funds are not accessible until retirement or separation of service.
All National Insurance Services’ HRA clients will receive additional guidance and reporting details from their HRA administrator, MidAmerica Administrative and Retirement Solutions after the end of the calendar year. MidAmerica will be tracking employees who do not have employer-sponsored health coverage as well as those who are not yet eligible for Medicare. In addition, part of the new reporting requirements is collecting dependent census information. Since this information was not required previously, a new enrollment procedure will be implemented to obtain this data moving forward. This is why the IRS is implementing the “good faith effort” to complete reporting as many employers may not readily have this information.
For more information on 6055/6056 reporting guidance, visit our resource page, or contact Beth Lauck, Retirement Income Service Manager at National Insurance Services at 800.627.3660 or MidAmerica at 800.430.7999.