Pay or Play, or Individual Mandate? Understanding the ACA

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Employer Reporting under the ACA

If you were thinking that the Internal Revenue Code was looking a bit heftier these days, you’re right. The ACA added two sections related to health insurance reporting: there is the “individual mandate report” or Section 6055 and the “pay or play report” or Section 6056. The IRS has released final guidance in March to streamline reporting requirements.
Section 6055 requires health insurers and sponsors of self-funded plans to report whether coverage offered by the employer constitutes minimum essential coverage under the ACA. This information will help the IRS enforce the individual mandate, in a way similar to the use of the 1099 HC in Massachusetts now. Section 6056 requires large employers to report to the IRS and full-time employees the cost of health benefits to help determine the employer shared responsibility as well as help employees determine their eligibility for a premium subsidy.

Required Information

For employers, insurers and other reporting entities to report information including:

For §6055 For §6056
Information about the entity providing coverage including contact information Information about the employer offering coverage, including contact information and the number of employees
Which individuals are enrolled in coverage, with identifying information and months for which they were covered For each full-time employee, information about the coverage offered by month, including the lowest employee cost of self-only coverage


Employers that self-insure will have a single consolidated report for both the employer and insurer reporting provisions. Additionally, if a qualifying offer is made to employees for all 12 months of the year, companies will be able to report just the names, addresses and taxpayer identification number for each individual. Otherwise, fully-insured employers will complete Form 6056 and insurers will be responsible for Form 6055.

For more information, contact Margaret Short, Vice-President of Benefits, at

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