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FlexMagic Consulting, Inc. specializes in design, implementation, administration and support of Premium-Only-Plans (POP), Flexible Benefit Plans (FBP) and Health Reimbursement Arrangements (HRA). We also integrate Health Savings Accounts (HSAs) and offer debit cards, online enrollment and online claims processing.
FlexMagic was originally founded in 1987 as part of Lidke & Associates Inc. and became a separate entity in 2003. It works with any size employer as part of the benefit team to help ensure the tax-free benefit programs are compliant under today's regulations. FlexMagic specializes in effective employee communications and its client retention has exceeded 90% every year since 1987. We hope you will give us the opportunity to make your company one of our valued clients.
IMPORTANT!!!! New HRA Reporting for 2015 - 6055 and 6056 HRA Reporting Overview
Please note: The information provided below is solely for the purpose of reporting HRAs, it not for reporting major medical.
FlexMagic will be available to assist. It will be the ultimate responsibility of the employer to make sure the reporting is filed.
6055 HRA Reporting (Required for all HRAs with the exception of most excepted benefits as discussed below)
The 2015 instructions state that a coverage provider providing more than one type of minimum essential coverage to an individual needs to report only one type of coverage. Thus, an employer sponsoring both a self-insured major medical plan and an HRA is required to report coverage under either the major medical plan or the HRA, but not both. And a minimum essential coverage provider does not have to report coverage for which an individual is eligible only because the individual has other minimum essential coverage for which reporting is required. Therefore, an employer sponsoring both a fully insured major medical plan and an HRA for employees enrolled in the major medical plan is not required to report the coverage under the HRA for an individual covered by both arrangements. The employer only needs to report the major medical in this case. However an applicable large employer must report the HRA coverage for any individual who is not enrolled in the employer's major medical plan (e.g., if the individual is enrolled in a group health plan of another employer (such as spousal coverage).
6056 HRA Reporting (Required for all Applicable Large Employers - 50 or more full-time or equivalent employees)
HRA Reporting. An applicable large employer - ALE (50 or more full-time or equivalent employees) with a self-insured major medical plan and HRA is required to report the coverage of an individual enrolled in both types of minimum essential coverage in Part III of Form 1095-C under only one of the arrangements. An applicable large employer with a fully-insured major medical plan and an HRA is not required to report the HRA coverage if the individual is eligible for the HRA because the individual enrolled in the insured major medical plan (integrated). However an applicable large employer must report the HRA coverage for any individual who is not enrolled in the employer's major medical plan (e.g., if the individual is enrolled in a group health plan of another employer (such as spousal coverage).
Excepted benefits are not considered health coverage and are therefore not required to report 6055 if they are offered separately or are not an integral part of the plan, such as a Medical Spending Account or a Limited-Scope Dental and/or Vision Plan.
Effective Date for both 6055 and 6056 Reporting
Code § 6055 and Code § 6056 reporting originally was to apply to coverage provided on or after January 1, 2014, but the IRS delayed reporting for one year. Under the final regulations, reporting is required under Code § 6055 and Code § 6056 beginning in early 2016 to report coverage provided in 2015.
When Is Reporting Required to Begin for Non-Calendar-Year Plans? Although transition relief is available to qualifying non-calendar-year plans with respect to some aspects of compliance with health care reform, such as employer shared responsibility, the information reporting requirements under Code § 6055 and Code § 6056 apply on a calendar-year basis, without regard to the plan year of the plan through which coverage is provided. Thus, reporting for all non-calendar-year plans begins in early 2016 as well and applies to the entire 2015 calendar year.
Reporting Deadlines for both 6055 and 6056 Reporting
The reporting entity (e.g., health insurers and employers sponsoring self-insured plans) must prepare separate information returns for individuals, furnish the individuals with copies of the information returns and use a single transmittal form to file the individual information returns with the IRS. The IRS has released final 2015 versions of the forms and instructions in anticipation of the mandatory filing first required in 2016 (for 2015 coverage).
Furnishing statements to "responsible individuals (participants)," the deadline is January 31 of the following calendar year. The regulations provide for an extension of time to furnish statements, including up to 30 days for a showing of good cause upon written application to the IRS.
For filing the return and transmittal with the IRS, the deadline is February 28 (March 31 if filed electronically) of the following year. An extension of time may be available for filing the return and transmittal. The 2015 instructions explain that filers can obtain an automatic 30-day extension by submitting IRS Form 8809 to the IRS on or before the due date. Note that proposed regulations would eliminate the automatic extension (for these and certain other information returns) and permit only a single 30-day extension with IRS approval in extraordinary circumstances. The proposed regulations do not affect filings for 2015; if finalized, they would take effect no earlier than January 1, 2018.
Mark Your Calendars: Code § 6055 and Code § 6056 Reporting. The first individual statements will be due by Monday, February 1, 2016, since January 31, 2016 falls on a Sunday. Paper returns filed with the IRS will be due on Monday, February 29, 2016. And returns filed
electronically will be due on Thursday, March 31, 2016.
Note: ALE members filing fewer than 250 returns during the calendar year may choose to make the Code § 6056 returns on the prescribed paper form, but are permitted (and encouraged) to file Code § 6056 returns electronically.
Electronic filing is required by ALE members who are high-volume filers (those who file at least 250 returns under Code § 6056). The proposed regulations would have required electronic filing if the ALE member filed 250 information returns of any type; e.g., Forms W-2 and 1099. But under the final regulations, the 250 return threshold is applied separately for each type of form. Thus, each Code § 6056 return for a full-time employee is counted as a separate return, and an ALE member will need to file Form 1095-C electronically with the IRS only if it is required to prepare forms for at least 250 employees. Like transmittals of other information returns, the transmittal (Form 1094-C) is not treated as a separate return but must be electronically filed in the form and manner required by the IRS if the Form 1095-C is required to be filed electronically. A waiver may be requested from the electronic filing requirement by submitting IRS Form 8508 at least 45 days before the due date of the returns.
Affordable Care Act Information Returns (AIR) Program (you must register and go through testing prior to reporting)
Deciphering the Form Numbers. The IRS has issued reporting forms; there are four relevant forms: 1094-B, 1095-B, 1094-C, and 1095-C.
Brief summary of the purpose of each form (links to forms and instructions are listed below):
1094-B: These forms are used to transmit individual statements (Forms 1095-B) containing Code § 6055 information to the IRS.
1095-B: These forms are used to report Code § 6055 information to responsible individuals.
1094-C: These forms are used by applicable large employers to transmit employee statements (Forms 1095-C) containing Code § 6056 information (and, for self-insured plans, Code § 6055 information) to the IRS.
1095-C: These forms are used by applicable large employers to report Code § 6056 information (and, for self-insured plans, Code § 6055 information) to employees.
Where to File
Send all information returns filed on paper to the following: If your principal business, office or agency, or legal residence in the case of an individual, is located in: Use the following address:
Alabama, Arizona, Arkansas, Connecticut, Delaware, Florida, Georgia, Kentucky, Louisiana, Maine, Massachusetts, Mississippi, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Ohio, Pennsylvania, Rhode Island, Texas, Vermont, Virginia, West Virginia Department of the Treasury Internal Revenue Service Center Austin, TX 73301
Alaska, California, Colorado, District of Columbia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Maryland, Michigan, Minnesota, Missouri, Montana, Nebraska, Nevada, North Dakota, Oklahoma, Oregon, South Carolina, South Dakota, Tennessee, Utah, Washington, Wisconsin, Wyoming Department of the Treasury Internal Revenue Service Center Kansas City, MO 64999
If your legal residence or principal place of business or principal office or agency is outside the United States, file with the Department of the Treasury, Internal Revenue Service Center, Austin, TX 73301.
Filing Returns with the IRS
Shipping and mailing. If you're filing on paper, send the forms to the IRS in a flat mailing (not folded). If you're sending many forms, you may send them in conveniently-sized packages. On each package, write your name, number the packages consecutively, and place Form 1094-B in package number one. Postal regulations require forms and packages to be sent by first-class mail.
Keeping copies. Generally, keep copies of information returns you filed with the IRS or maintain the ability to reconstruct the data for at least 3 years, from the due date of the returns.
Q&As per the IRS (very helpful):
Forms and Instructions for filing 1094B and 1095B:
Forms and Instructions for filing 1094C and 1095C: