I believe all filings with the IRS should be reviewed by a Tax Manger or designated tax person at each school. I would hope that HR would seek the advice of tax counsel before filing these returns. If you are a Tax Manager, you should ask to review and be responsible for the correct filing.
All providers of health coverage, including employers that provide self-insured coverage, must file annual returns with the IRS reporting information about the coverage and about each covered individual. Insurance Companies must report on coverage under employer plans that are insured.
Employers should report this information on Forms 1094-B and 1095-B or on Forms 1094-C and 1095-C, depending on whether the employer is an applicable large employer for purposes of the employer shared responsibility provisions.
If an employer providing self-insured coverage is an applicable large employer, it generally reports information regarding coverage of an individual on Form 1095-C instead of Form 1095-B. Form 1095-C combines reporting for two provisions of the Affordable Care Act for these employers. However, when reporting coverage of an individual who was not a full-time employee for any month of the year, an applicable large employer may choose to use Form 1095-B.
The information reporting requirements are first effective for coverage provided in 2015. Thus, health coverage providers will file information returns with the IRS in 2016, and will furnish statements to individuals in 2016, to report coverage information in calendar year 2015.
The information that a provider must report to the IRS includes the following:
- The name, address, and employer identification number of the provider.
- The statement recipient’s name, address, and taxpayer identification number, or date of birth if a TIN is not available. If the statement recipient is not enrolled in the coverage, providers may, but are not required to, report the TIN.
- The name and TIN, or date of birth if a TIN is not available, of each individual covered under the policy or program and the months for which the individual was enrolled in coverage and entitled to receive benefits.
For more information, see this link for questions and answers:
http://www.irs.gov/Affordable-Care-Act/Questions-and-Answers-on-Information-Reporting-by-Health-Coverage-Providers-Section-6055 on Information Reporting by Health Coverage Providers on IRS.gov/aca.
Employers who provide self-insured coverage should review Publication 5215 at this link:
http://www.irs.gov/pub/irs-pdf/f5215.pdf Responsibilities for Health Coverage Providers.
Applicable large employers should review Publication 5196 at this link
http://www.irs.gov/pub/irs-pdf/p5196.pdf , Reporting Requirements for Applicable Large Employers.