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ACA Reporting Requirements for Carriers and Employers (Part 10 of 24): Final Instructions for 2015 Reporting -- Good News for HRAs, Changes to COBRA Reporting, Clarifications for Multiemployer Plans, and More
Mintz LevinLink to more items from this source
[Guidance Overview]
Sept. 22, 2015

"The 2015 Instructions for Forms 1094-B and 1095-B implement a suggestion ... relating to the reporting of Health Reimbursement Arrangements (HRAs) that are integrated with other group health plan coverage. The 2015 Instructions for Forms 1094-C and 1095-C make a substantive change in the manner in which offers of COBRA coverage are reported and clarify the reporting of multiemployer plan coverage. The Treasury Department and IRS also issued Notice 2015-68, which announces their intent to propose regulations to reflect recent changes in the law ... and to clarify existing regulations (e.g., the reporting of coverage under integrated HRAs)[.]"

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