ACA Reporting Road Map

ACA Reporting Requirements FAQs

Beginning in 2014, most Americans were required to obtain minimum essential coverage or pay a penalty (known as the "individual mandate"). These forms will assist the IRS in identifying which individuals were offered or had coverage through their respective employers.

Additionally, the information provided on these reports will be used to determine if an Applicable Large Employer member will be subject to the employer mandate penalty, and if an individual is eligible for a premium tax credit.

No. Employers with fewer than 50 full-time and full-time equivalent (FTE) employees (non-ALE members) that do not offer health coverage are not subject to the reporting requirements. Additionally, non-ALE members that offer fully insured health coverage are not subject to the reporting requirements; their insurance carrier is responsible for reporting. Employers with 50 or more full-time and FTE employees must complete and file Forms 1095-C and 1094-C, regardless of the type of coverage they provide.

It depends. If you offer fully insured coverage, the insurer is responsible for reporting. If you are a non-ALE member and you are self-insured (or level-funded), you will need to complete Forms 1095-B and 1094-B.

For the 2018 tax year, employers subject to reporting must provide the forms to their employees by March 4, 2019, after the IRS pushed back the due date, which was originally January 31. Additionally, employers must file the forms with the IRS by February 28, 2019 (or April 1, 2019, if filing electronically).

Among other things, you will report information such as:

  • The name, address and Social Security Number of all full-time employees;
  • The name, address and Social Security Number of all individuals (employees, spouses, dependents and others) who are covered under your group health plan;
  • For each month, whether coverage was offered and to whom it was offered;
  • The employee’s share of the monthly premium for the lowest cost self-only coverage;
  • The months during which the individual had at least one day of coverage.

You should start gathering the information by the end of the calendar year so that you have the necessary data to complete the forms early the next year. Employers that fail to meet applicable reporting requirements may be subject to penalties (for 2018, the maximum penalty is generally $270 per form — $540 if the employer violates the requirements for both forms).

Employers are encouraged to seek assistance through legal counsel, tax professionals, or insurance brokers when filing these forms. For more information, see the FAQs provided by the IRS.