ACA Reporting Road Map
The Affordable Care Act (ACA) requires insurers, small employers with self-insured (including level-funded) health plans, and all Applicable Large Employers (those with 50 or more full-time and full-time equivalent (FTE) employees) to report certain information about health coverage to the Internal Revenue Service (IRS) and provide full-time employees and covered individuals with an annual statement. Note: Some states have recently enacted their own reporting requirements related to health coverage. Check your state law to ensure compliance.
Follow our ACA Reporting Road Map to find out if you need to report.
Table of Contents
Step 1: Calculate Full-time and FTE Employees
Use the FTE calculator in RUN Powered by ADP® (RUN) to determine your number of full-time and full-time equivalent (FTE) employees. In general, if you had a combined total of 50 or more full-time and FTE employees in the 2020 calendar year, you need to complete and file Forms 1095-C and 1094-C in 2022.
IMPORTANT: If you are part of a controlled group, you must combine all employees of each company when making this calculation.
Controlled groups exist when any two or more entities are treated as a single employer under section 414 (b), (c), (m), or (o) of the Internal Revenue Code. Where the combined total of full-time and FTE employees in a controlled group is 50 or more, each individual employer is subject to reporting with respect to its own common law employees (or prior employees).
Fewer than 50?
No action is needed, unless you are self-insured or have a level-funded plan. A self-insured plan generally means that the employer assumes the risk of paying participants' claims out of its general assets or a trust. A level-funded plan is a type of self-insured plan where rates are based on group experience. They typically have fixed monthly payments that are used to pay claims and maintain stop-loss coverage.
If you have fewer than 50 full-time and FTE employees and don't offer health coverage, you are not subject to these reporting requirements. If you have fewer than 50 full-time and FTE employees and offer a fully insured health plan, your insurer is responsible for filing the required forms with the IRS and furnishing the forms to your employees.
50 or more?
If you have 50 or more full-time and FTE employees, or you offer a self-insured (or a level-funded) health plan, proceed to Step 2.
Step 2: Consider Coverage Type
If you have fewer than 50 full-time and FTE employees and don't offer health coverage, you are not subject to these reporting requirements. If you are a small employer that offers health coverage, your insurer will report on your behalf, unless you are self-insured.
Here is an overview of each type of plan:
- Fully Insured Health Plan: Generally, a type of plan purchased by the employer from an insurance company where the insurance company assumes the health coverage risk. Most employers offer fully insured health plans.
- Self-Insured Health Plan: Generally, a type of plan where the employer assumes the risk of paying participants' claims out of its general assets or a trust.
- Level-Funded Health Plan: Generally, a type of self-insured plan where rates are based on group experience. They typically have fixed monthly payments that are used to pay claims and maintain stop-loss coverage. For instance, one-year rates may be low due to a healthy population of the group but that could change the next year due to illness/injury in the group.
Proceed to Step 3 to determine which forms to file.
Step 3: Identify Forms to File
Proceed to Step 4 for forms and instructions.
Step 4: Gather Information
Once you have identified which forms you need to file, gather the information necessary to complete them. Depending on your situation, this may include, but is not limited to:
- Employee's name, SSN, and address;
- Employer's name, EIN, telephone number, and address;
- For each month, whether coverage was offered and to whom it was offered (e.g., employee only; employee and dependents);
- The employee's share of the monthly premium for the lowest cost self-only coverage;
- Each covered individual's (including the employee and his or her spouse and/or dependents) name, SSN or date of birth (if SSN is unavailable), and the months he or she was covered by the plan for at least one day.
The IRS hasn’t released final versions of the forms due in 2022 yet. Once the IRS does, they will be available below.
To help you complete the forms, RUN Powered by ADP® (RUN) has an export tool that provides you with your employees' demographic information. Sign in to RUN and use the export tool to start gathering relevant employee information. Pull the data again if you have a new hire or make any changes to employee information before the filing deadline. Note: You will need to work with your insurance carrier or benefits administrator to obtain the health coverage information needed to complete the remainder of the forms.
For a list of vendors that may be able to help you complete your ACA forms, click here.
Proceed to Step 5 for guidelines on how to communicate with your employees about the new forms.
Step 5: Communicate with Employees
Let your employees know that they will receive the employee statement in January and that they will need it to prepare their tax return. If your insurer is responsible for providing the forms, consider coordinating your communication strategy with your insurer.
Here are sample communications that you can use as a model, depending on the size of your company and the type of coverage you offer.
- Sample ACA Communication 1: For employers with 50 or more full-time and FTE employees that offer fully insured health plans
- Sample ACA Communication 2: For employers with 50 or more full-time and FTE employees that offer self-insured (or level-funded) health plans
- Sample ACA Communication 3: For employers with fewer than 50 full-time and FTE employees that offer fully insured health plans
- Sample ACA Communication 4: For employers with fewer than 50 full-time and FTE employees that offer self-insured (or level-funded) health plans