ACA Reporting Requirements

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The Affordable Care Act added sections 6055 and 6056 to the Internal Revenue Code which requires employers to file information returns and furnish statements to individuals about their health insurance coverage.
6055 (Reporting by Health Coverage Providers)6056 (Reporting by Employers for Offers of Health Insurance)
Group SizeAll employers that provide health coverageApplicable Large Employers (ALE's) with 50 or more full-time equivalent employees
Reporting DeadlineJanuary 31, 2016 to employees
February 28, 2016 to IRS (if employer reports on paper)
March 31, 2016 if employer reports electronically
January 31, 2016 to employees
February 28. 2016 to IRS (if employer reports on paper)
March 31, 2016 if employer reports electronically
Required Forms1095-B (Health Coverage)
1094-B (Transmittal of Health Coverage Information Returns)
1095-C (Employer Provided Health Insurance Offer and Coverage)
1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns)
Reported byFully-Insured Plans: Insurer
Self-Insured Plans: Employer
Fully-Insured Plans: Employer
Self-Insured Plans: Employer
Required Information1095-B reports the name, address and social security number of all individuals (employees, spouses, dependents and otheres) who are covered under an employer's medical plan and the number of months during which the indivudal had at least one day of coverage.1095-C is a monthly collection of an employee's name, address, and social security numbers, whether the employee and their dependents were offered health coverage each month that met the minimum value standard, the employer's share of the monthly premium for the lowest-cost minimum value health coverage offered, whether the employee was full time, whethe the employee was enrolled in the health plan, plus additional information.
WhyThe information provided in this reporting will allow the IRS to verify whcih individuals have been enrolled in minimum essential coverage through a employer, thereby, avoiding the individual mandate penalty tax.The IRS will use the information reported on form 1095-C to determine whether an employer is assessed a penalty tax. This form will also be used to determine whether an employee is eligible for premium tax credits if they purchased coverage through their state's marketplace.
PenaltyUp to $500 per return for failing to timely file the returns or furnish statements to employees.Up to $500 per return for failing to timely file the returns or furnish statements to employees.
Small Group (49 or less employees)Large Group (50 or more employees)
Fully InsuredFiles 1094-B & 1095-B (created by the insurance carrier or the SHOP marketplace and sent to the individual and IRS)Employer creates and files 1094-C & 1095-C all sections.
Self InsuredEmployer creates and files 1094-B & 1095-B
Employees who are offered coverage, but waive, are not reported.
Employer creates and files 1094-B & 1095-B, and 1095-C sections I, II
  • Applicable Large Employer’s (50+ employees) that do not offer insurance must still file 1094-C & 1095-C
  • The information provided under section 6055 is used to administer the individual shared responsibility provision in section 5000A.
  • The information provided under section 6056 is used by the IRS to administer the employee shared responsibility provision of section 4980H.
  • Entering into a reporting arrangement with a third party provider does not transfer the potential liability of the employer for failure to report information and furnish statements correctly.
  • You can get an automatic 30 day extension of time to file by complete Form 8809 – Application for Extensino of Time to File Information Returns.  No signature or explanation is required for the extension; howevver, you must file by the due date of the returns.
  • If you are an ALE with 250+ employees and wish to receive a waiver for filing electronically, you must complete Form 8508 and submit it at least 45 days before the due date.  This waiver will grant you to submit originals via mail, and submit any corrections via mail as well.  If you originally submitted your forms electronically, yet wish to submit your corrections via mail, you must complete Form 8508 and receive an approved waiver for your records.  If you are required to file electronically and fail to do so, you may be subject to a penalty of up to $250 per return.

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