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November 18, 2015

ACA Reporting Will Be Required for the 2015 Year

Year-end 2015 will bring new reporting requirements for employers for the Affordable Care Act (ACA). You may think this reporting only applies to organizations subject to the Employer Mandate (otherwise known as "Applicable Large Employers" (ALEs)) - those with more than 50 full-time-equivalent employees (FTEs), but that's not necessarily the case. Even small employers may have to comply with these reporting requirements if their group health plan is self-insured.

How do you keep these complicated
reporting requirements straight?

There are two kinds of forms - the "B" forms (1094-B and 1095-B) and the "C" forms (1094-C and 1095-C). An easy way to look at ACA reporting is by considering it similar to wage reporting using Form W-2. The 1095 forms are sent to EACH employee reporting their insurance coverage, much like W-2s are used to report wages. The 1094 forms summarize the underlying 1095 forms, much like Form W-3 summarizes all the wage statements.

"B" Forms

"C" Forms

Must be filed by:
- Insurance Companies
- Employers who are NOT Applicable Large Employers but who are sponsors of self-insured health plans. This means that small employers who are not subject to the employer mandate, but are self-insured, are subject to this reporting.

The purpose of the "B" forms is to report individuals who are covered by minimum essential coverage so that they won't be penalized for not having insurance.

Only filed by Applicable Large Employers (ALEs), regardless of whether the employer sponsors a group health plan, whether it is fully insured or self-funded, and even if the ALE is exempt from the employer mandate. The purpose of these forms is to report insurance offers and coverage for employees, to determine whether employers owe a penalty and to determine employee eligibility for the premium tax credit.

Reporting Requirements for Different Organizations

    Organization Size      

Group Health Plan   


Under 50 FTEs

Fully Insured

1094-B and 1095-B
No ACA Reporting Required

50-99 FTEs

Fully Insured

1094-C and 1095-C

100+ FTEs

Fully Insured

1094-C and 1095-C

When to File

Who to Contact
for Assistance

Regardless of which form you're required to file, they're due to employees by
February 1, 2016 (normally January 31, but that's a Sunday in 2016); and to the government by February 29, 2016 (if you're filing by paper) or by March 31, 2016 (if filed electronically).

Payroll Processing Companies

For employers who use a payroll processing company (such as Paycor, Paychex, ADP, etc.), these companies are offering ACA reporting services for an additional fee. Be sure to inquire through your payroll representative.

Insurance Brokers

Many local insurance brokers are also offering ACA reporting services. Contact your broker to inquire whether or not they are offering these services and what you need to do to ensure reporting compliance for your company.

It is imperative that you determine your solution to the required reporting NOW. Waiting until the end of the year could very well put you at risk of not having the resources available to comply in a timely manner. Failure to comply with these reporting requirements WILL result in substantial fines and penalties.