The Internal Revenue Code requires large employers to provide information to the IRS and their employees about whether they have offered employees minimum essential coverage that is affordable and provides minimum value. 

• The information must be provided on IRS Forms 1094-C and 1095-C
• The IRS will use these tax forms to determine whether an individual qualifies for subsidized coverage through a health insurance exchange (the insurance market set up in each state under the ACA to allow individuals to purchase health insurance coverage)

If you or an organization in your group is a large employer, you or that organization will be responsible for preparing and filing IRS Forms 1094-C and 1095-C. The Medical Trust will not prepare these tax forms.

• Large employers that do not sponsor an HRA will not need to complete Part III of Form 1095-C because that information will be included in Form 1095-B that either the Medical Trust or the insurer will prepare
• Large employers that sponsor an HRA may also be required to complete Part III of Form 1095-C for participants

The IRS has published instructions about this reporting obligation. Employers should review the tax forms and instructions carefully. To access these forms and instructions, click on the following links:

• Form 1094-C for large employers to transmit Form 1095-C
• Form 1095-C for large employers to report coverage offered to individuals under the employer mandate Instructions for Forms 1094-C and 1095-C

The Internal Revenue Code requires insurers and the sponsors of self-funded plans to disclose whether plan subscribers have obtained minimum essential coverage in compliance with the individual mandate.

• Organizations that participate in the Medical Trust plans will not be responsible for meeting this reporting requirement
  • ​Employers that sponsor an HRA may also be required to prepare separate 1094-B and 1095-B forms for participants. If you sponsor an HRA, please see Notice 2015-68 and consult your tax advisor
• As the designated plan sponsor of the self-funded medical plans, the Medical Trust will prepare IRS Forms 1094-B and 1095-B or, in the case of fully insured medical plans, the insurer will prepare these tax forms

The Medical Trust will report the required information to the IRS on Form 1095-B (and transmittal form  1094-B) for each plan subscriber and their covered dependents. The Medical Trust will also provide this tax form to plan subscribers. The insurance carriers for fully insured medical plans will meet this requirement for each of those plans.

The filing deadlines and the responsibility for the individual mandate forms are summarized below.

Note: To prevent the filing of duplicate tax forms with the IRS, it is important that you inform the organizations in your group that participate in the Medical Trust self-funded plans that the Medical Trust will prepare and file Form 1095-B and provide a copy to plan participants and the IRS. Insurers will be responsible for filing and distributing Form 1095-B for their medical plans. 

An exception may apply for small employers that sponsor an HRA.