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The guidance is provided in a question-and-answer format, with comments requested on several issues that the IRS plans to address in forthcoming rules. The Notice supplements previous guidance on several issues, including Health Reimbursement Arrangements (HRAs) and Employer Payment Plans, providing additional clarification and, in some cases, transition relief or grace periods for compliance.

All applicable large employersthose with 50 or more full-time employees, including full-time equivalents (FTEs) are required to report whether minimum value, affordable coverage was offered to any employees who were full-time for at least one month during the calendar year. And all employers sponsoring a self-funded medical plan are required to report on all individuals covered under the plan, even those who are not full-time employees. The employer will report the required information by using Forms 1094 and 1095 (B or C). Employers who must provide 250 or more Forms 1095 are required to file electronically.

This article focuses on an update on major insurance carriers in the third quarter of 2015.