The Affordable Care Act Reporting Requirements for Employers
The Affordable Care Act’s (ACA) purpose is to make health insurance coverage affordable and
available to everyone. The Individual Mandate requires all non-exempt individuals to maintain
minimum essential coverage (MEC) or pay a penalty. The providing of the Form 1095-B or
Form 1095-C to the employee/insured, will provide the documentation needed to determine
whether individuals are maintaining MEC.
The Employer Mandate requires applicable large employers (Employers with 50 or more full
time employees or full time equivalent employees. If you are part of a controlled group, you
must combine all employees of each company when making this calculation.), to offer affordable
health coverage that provides a minimum level of coverage to their full-time employees (and
their dependents) or be subject to an Employer Shared Responsibility payment. The Employer
Mandate also requires the employer to file returns with the IRS and provide statements to
employees outlining the health insurance coverage offered them. This information is used by
the IRS to determine if the employer has complied with the mandate. Employers and insurance
carriers as well, have to provide information via Form W-2, Forms 1094-B &1095-B and Forms
1094-C & 1095-C to help the IRS audit compliance. These informational forms will be due in
2016. Below is a short discussion on these forms:
Form W-2 Reporting:
This provision is intended to help employees understand their employer-provided benefits and
provide the true cost to obtain health coverage. Employers filing 250 or more Forms W-2 in the
previous tax year are required to report the total value of certain employer-sponsored health
benefits on employees’ forms. For employers filing less than 250 Forms W-2 in the previous tax
year, this reporting is optional. The total amount paid for employer-sponsored health coverage
(employee contribution plus employer contribution) is reported on Form W-2, box 12, Code DD.
The W-2’s need to be provided to the employees no later than February 1, 2016 and filed
with the IRS no later than February 29, 2016.
Forms 1094-B and 1095-B:
These forms are prepared by the entity that is providing insurance. Insurance companies will be
providing this to the insured and the IRS. Small employers (less than 50 full time employees or
full time equivalent employees) who are self-insured will also have to provide this form to their
employees and the IRS. The Form 1094-B is used to report to the Internal Revenue Service
summary information for each insured and to transmit Forms 1095-B to the Internal Revenue
Service. Form 1095-B is used to report information about each insured and is provided to the
The Forms 1095-B’s need to be provided to the Employee/Insured no later than January
31, 2016. The Form 1094-B needs to be filed with the IRS by February 29, 2016.
Forms 1094-C and 1095-C:
Employers, with 50 or more full-time employees (including full-time equivalent employees), are
required to use these forms to report information about offers of health coverage and enrollment
in health coverage for their employees. The Form 1094-C is used to report to the Internal
Revenue Service summary information for each employer and to transmit Forms 1095-C to the
Internal Revenue Service. Form 1095-C is used to report information about each employee and
is provided to the employee.
The Forms 1094-C and 1095-C are used in determining whether an employer owes a payment
under the employer shared responsibility provisions under the ACA. Form 1095-C is provided
to the employees to use in determining the eligibility of the employees for the premium tax
Filing due date with the Employee is January 31, 2016.
Filing due date with the IRS is February 29, 2016.
See the flowchart below provided courtesy of ADP to assist you in determining what your filing
requirements may be.
ACA Annual Reporting Flowchart