ACA Information Reporting: §6055 and §6056

Purpose and Relationship of the Two Provisions

The Affordable Care Act added two information-reporting regimes to the Internal Revenue Code. They serve different administrative purposes and can apply to the same employer at the same time.

Section 6055 supports administration of the coverage rules: it tells the IRS, and the covered person, who actually held minimum essential coverage (MEC) and for which months. Section 6056 supports administration of the employer shared responsibility provisions of §4980H and the premium tax credit of §36B: it tells the IRS what coverage an applicable large employer (ALE) offered to each full-time employee, on what terms, and for which months.

The practical consequence of having two regimes is that the reporting obligation depends on two independent questions: whether the entity provided MEC (the §6055 question) and whether the employer is an ALE (the §6056 question). An employer can be subject to one, both, or neither, and the form path follows from the combination.