IRS Reporting Guidelines

• Sections 6055 and 6056 Reporting
• W-2 Reporting for Local Churches and Other Employers

Sections 6055 and 6056 Reporting

The General Board has developed guidelines to help annual conferences, local churches and other United Methodist Church (UMC) employers comply with various reporting requirements under the Affordable Care Act (ACA, also called federal health care reform) and other Internal Revenue Service (IRS) guidance. These documents are available on the General Board’s health care reform web page.

Section 6055 Reporting—Minimal Essential Coverage: IRS Forms 1095-B and 1094-B
Section 6055 reporting focuses on the “individual mandate” that requires most U.S. citizens and legal resident aliens to maintain health coverage or pay a penalty.

• For HealthFlex plan sponsors: The General Board will complete Section 6055 reporting for coverage administered by HealthFlex.
• For annual conferences and other employers that sponsor self-insured health plans: The annual conference/employer must complete Section 6055 reporting.
• For annual conferences and employers that sponsor fully insured health plans: The health insurance policy issuer should complete Section 6055 reporting.

Section 6056 Reporting—Employer-Provided Health Insurance: IRS Forms 1095-C and 1094-C
Section 6056 reporting focuses on the “employer mandate” that requires applicable large employers (i.e., those with 50 or more full-time and full-time equivalent employees) to offer affordable health coverage or pay a penalty. Section 6056 reporting does not apply to smaller employers.

• For HealthFlex plan sponsors: Applicable large employers must complete Section 6056 reporting.
• For annual conferences and other employers that sponsor self-insured health plans and are applicable large employers: Conference offices and other salary-paying units that are applicable large employers must complete Section 6056 reporting.
• For annual conferences that sponsor fully insured health plans and are applicable large employers: Conference offices and other salary-paying units that are applicable large employers must complete Section 6056 reporting.

Please note: The Employer Shared Responsibility Toolkit on the health care reform web page provides detailed information to help annual conferences, churches and other UMC employers determine whether they are “applicable large employers” under ACA guidelines.

W-2 Reporting for Local Churches and Other Employers

Church treasurers and other payroll administrators must report health savings account (HSA) and dependent care flexible spending account (dependent care FSA) contributions on IRS W-2 forms provided to employees. IRS W-2 Reporting Responsibilities for Employers is aimed at HealthFlex plan sponsors, but the guidelines may also be useful for local churches and other UMC employers outside of HealthFlex.

Please direct any questions about Section 6055, Section 6056 and W-2 reporting to healthcarereform@gbophb.org. Check the health care reform web page for future updates.

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