Regulatory roundup

More healthcare-related regulatory news for plan sponsors, including links to detailed information.

Changes made to instructions for Forms 1094-B and 1095-B
The Internal Revenue Service (IRS) has issued changes to the instructions for Forms 1094-B and 1095-B before December 2, 2015. Note the following changes.

On page 7, under the Specific Instructions for Part IV, column (c), the format of the characters to list for date of birth is incorrect. The correct format is “YYYY-MM-DD.” The formatting directions in these instructions—for example, the directions to enter the nine-digit Employer Identification Number (EIN), including the dash on page 6 for Line 2 of the Form 1095 B—are for the preparation of paper returns. When filing forms electronically, the formatting set forth in the XML Schemas and Business Rules, published on irs.gov, must be followed rather than the formatting directions in these instructions. For more information regarding electronic filing, see Publications 5164 and 5165.

Changes made to instructions for Forms 1094-C and 1095-C
The IRS has issued changes to the instructions for Form 1094-C and 1095-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return, before December 2, 2015. Note the following changes.

On page 12, under the Specific Instructions for Part IV, column (c), the format of the characters to list for date of birth is incorrect. The correct format is “YYYY-MM-DD.” The formatting directions in these instructions (for example, the directions to enter the nine-digit EIN, including the dash on page 5 for Line 2 of the Form 1094-C) are for the preparation of paper returns. When filing forms electronically, the formatting set forth in the XML Schemas and Business Rules, published on irs.gov, must be followed rather than the formatting directions in these instructions. For more information regarding electronic filing, see Publications 5165 and 5164.

IRS issues Publications 5165 and 5164
IRS Publication 5165 outlines the communication procedures, transmission formats, business rules, and validation procedures for returns transmitted electronically through the ACA Information Returns (AIR) Program system. The procedures in this publication should be used when the following information returns are transmitted electronically: Form 1094-B, Transmittal of Health Coverage Information Returns; Form 1095-B, Health Coverage; Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns; and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage.

For more information, click here.

Software developers are required annually to pass predefined ACA Assurance Testing Systems (AATS) submissions and test scenarios for the forms that they will support. Transmitters and issuers are required to pass communication tests for the forms they will file. IRS Publication 5164 is for the more robust AATS testing environment beginning January 2016. This testing environment will provide additional improved error messages for business rule execution errors and will not use the character-by-character comparison tool for submission evaluation. Please note, if the tests were passed in the November AATS environment, passing the more robust January AATS is not required.

For more information, click here.

IRS issues compliance questions on 2015 Form 5500 series returns
The IRS has introduced new compliance questions regarding 2015 Form 5500 series returns. These questions will help the IRS effectively focus on specific factors and issues of federal tax law compliance. Responses to these new questions are optional for the 2015 plan year.

For more information, click here.