Who Completes What?

18 Feb Who Completes What?

Below please find a brief summary of the ACA reporting requirements (Forms 1094/1095) along with an overview of responsible parties:

  • Who Must Complete Form 1095-C?
    • If you are an Applicable Large Employer (ALE), you must provide your full-time employees with Form 1095-C (regardless of whether you are offering fully or self-insured health coverage) in addition to any part-time employees offered health coverage under your self-funded plan


  • Who Must Complete Form 1095-B?
    • If you are not an ALE and you sponsor a self-funded plan, report such coverage on Form 1095-B to any employees covered under that plan
    • Regardless of whether you are an ALE, if you sponsor a fully-insured health plan, your insurance carrier will report that coverage to your covered employees on Form 1095-B


  • Transitional Relief 2015. Exemption from ‘Pay or Play’ Penalty for Employers with 50-99 full time employees and full-time equivalents


  • Deadline: March 31, 2016 (extended from February 1, 2016)


  • Who Must Complete Form 1094-C?
    • An ALE must file the individual reports (1095-C), along with a transmittal report (1094-C) with the IRS
    • Employers who issue 250 or more individual reports must file electronically (whether fully or self-insured)


  • Who Must Complete Form 1094-B?
    • An employer of any size that provides self-funded health coverage must send an individual report (Form 1095-B) and also file the individual reports and a transmittal report (Form 1094-B) with the IRS


  • Deadline: May 31, 2016 (if not filing electronically) and June 30, 2016 (if filing electronically)


Anne Tyler Hall, ERISA & Benefits Attorney at Hall Benefits Law