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Employer Reporting Requirements under ACA

Update 11/18/2016: The IRS extended the deadline for providing the statements to employees/individuals in 2017. 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 coverage or only offered fully insured coverage are not subject to the reporting requirements summarized in this article. All other employers are.

The IRS modified the forms for 2016. Read a summary of the most notable changes.

Reporting Required from Large Employers

Applicable Large Employers (ALEs), generally groups that employed 50 or more employees, are required to report under Section 6056 about the employees who were offered health coverage during the prior calendar year. Large employers who offered self-funded coverage must include information about the employees and dependents covered by the plan (Section 6055).

Resource Deadline Notes
IRS Transmittal Form 1094-C Mar 31 (if electronic) or
Feb 28 (if paper)
Send to the IRS along with copies of all Forms 1095-C. Employers filing 250+ Forms 1095-C must file electronically.
Employee Statements Form 1095-C Mar 2 (in 2017 only) Send to each person who was a full-time employee at any point in calendar year and to the IRS. Employers who did not offer a self-funded plan will ignore Part III. Deadline for 2017 was extended. Standard deadline is Jan 31.
Instructions PDF, HTML Official IRS instructions.
IRS Resources Sec 6056 Q&A
Forms Q&A
General info

Reporting Required from Small Employers about Self-Funded Plans

All employers who offer self-funded plans must provide annual statements to employees and information returns to the IRS about the type and period of coverage provided to each individual who was enrolled in the health plan in the prior calendar year. The IRS uses this reporting to administer the individual mandate and subsidies in the individual market.

Small employers who are not considered Applicable Large Employers use the B-series forms linked below. These forms exclude information specific to the employer mandate and are only used by employers who are not considered Applicable Large Employers. Large employers who are subject to the employer mandate do not use these forms. They use the C-series forms linked above.

Resource Deadline Notes
IRS Transmittal Form 1094-B Mar 31 (if electronic) or
Feb 28 (if paper)
Send to the IRS along with copies of all Forms 1095-B.
Employee Statements Form 1095-B Mar 2 (in 2017 only) Send to each covered individual. Deadline for 2017 was extended. Standard deadline is Jan 31.
Instructions PDF, HTML Official IRS instructions.
IRS Resources Sec 6055 Q&A
MEC Reporting Info

Additional Resources

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