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Health Care Reform: IRS Issues Proposed Regulations on the Reporting Requirements


September 2013

The IRS released proposed regulations on the Affordable Care Act’s reporting requirement applicable to insurers and self-insured health plan sponsors that provide “minimum essential coverage,” and the reporting requirement applicable to large employers to report coverage provided to full-time employees. The proposed regulations address the following two mandates:

  1. Under Internal Revenue Code Section 6055, any person who provides “minimum essential coverage” to an individual during a calendar year must report the coverage information to the IRS. The reporting person must also provide a written statement to the covered individual; and
  2. Under Internal Revenue Code Section 6056, employers must report to the IRS whether they offer their full-time employees and their employees' dependents the opportunity to enroll in “minimum essential coverage” under an eligible employer-sponsored plan and to provide certain other information. Reporting employers must also provide a related written statement to their full-time employees.

The first reporting will not be required until early 2016 (for health coverage provided in 2015).

Health Care Reform: IRS Issues Notice on High Deductible Health Plans and Mandated Preventive Care
The IRS issued Notice 2013-57 clarifying that a health plan will not fail to qualify as a high deductible health plan under Code Section 223(c)(2) if the plan provides the preventive health services required by Public Health Service Act Section 2713, without a deductible.

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