Federal paperwork reviewers recently signed off on a major package of Patient Protection and Affordable Care Act (PPACA) forms.
The package includes Form 1094-C, which is the form employers are supposed to use to tell the IRS whether they offered workers minimum essential coverage (MEC), and Form 1095-C, which is the form employers are supposed to use to tell the workers themselves whether they had or were offered MEC.
See also: IRS redesigns PPACA coverage notice drafts.
Employers can send 1095-C forms to workers this year, for the 2014 plan year, if they want to.
“Applicable large employers” will have to send 2015 plan-year forms to workers by Jan. 31, 2016.
Elizabeth Vollmar, a compliance lawyer at Lockton Companies, says in a commentary that the final IRS instructions for the forms will create a massive data collection and assimilation effort.
The bad news, she says, is that the IRS left the draft forms as is.
The good news is that employers and others who assumed the final forms would look like the draft forms can continue to move forward with the data-gathering efforts they’ve been developing.
For a look at some of the gremlins commenters found in the draft versions of the forms, read on.
1. Mailing monsters
Jonathan Foley, a director at the U.S. Office of Personnel Management (OPM) — the benefits office for IRS workers and other federal workers — has written to ask whether OPM really has to mail the 1095-C forms to federal employees.
Most federal employees already can see paystubs, W-2 forms, W-4 forms and other forms online, and OPM could easily put the 1095-C forms in the same system, Foley says. If regulators would let OPM deliver the forms electronically, that would save taxpayers millions of dollars, he says.
2. Time monsters
Several commenters note that employers, insurers and outside plan administrators are rushing to try to comply with complicated, rapidly changing PPACA-related rules and regulations.