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Employer Reporting Requirements under the ACA

Update 11/29/2018: The IRS extended the deadline for providing the statements to employees/individuals in 2019. No extension for the IRS filing deadlines.

Applicable Large Employers and all employers who offer self-funded plans are required to provide annual statements to employees and information returns to the IRS about the health coverage they offered (or did not offer) in the prior year. The IRS uses the statements and returns to confirm compliance with the employer and individual mandates and to administer subsidies in the individual market. Small employers who did not offer any coverage or only offered fully insured coverage are not subject to the reporting requirements summarized in this article. All other employers are.

The reporting is comprised of two forms:

  1. Employee Statements – Form 1095 – Employer sends statements to each employee and files the statements with the IRS in conjunction with a summary transmittal.
  2. IRS Transmittal – Form 1094 – Employer reports summary information to transmit with the employee statements.

Reporting Required from Large Employers

  • Generally, Applicable Large Employers (ALEs) are groups that employed 50 or more full time (and equivalent) employees. See Determining if an Employer is an Applicable Large Employer.
  • ALEs use the C-series forms (1094-C and 1095-C).
  • ALEs provide statements to each employee who was full time at any point in the year about the coverage offered (or not offered) and enrollment in that coverage.
  • ALEs who offered self-funded coverage complete Part III of each statement listing the employee and dependents covered by the plan and the period of coverage for each.
  • ALEs filing 250+ Forms must file electronically.

Reporting Required from Small Employers about Self-Funded Plans

  • Reporting applies to small employers—employers who are not ALEs—who offered self-funded coverage.
  • Small employers with self-funded plans use the B-series forms (1094-B and 1095-B).
  • Employers provide statements to individuals covered by the self-funded plan at any point during the year.

IRS Forms and Guidance

 Large Employers (ALEs)Small Employers with Self Funded PlansDeadline
Employee StatementsForm 1095-CForm 1095-BMar 4 (in 2019 only)
IRS TransmittalForm 1094-CForm 1094-BApr 1 (if electronic) or
Feb 28 (if paper)
InstructionsPDF, HTMLPDF, HTML
IRS ResourcesReporting Q&A
Forms Q&A
General Info
Reporting Q&A
General Info

Additional Resources

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