ACA Reporting Reminder: Electronic Filing Deadline

Applicable Large Employers (ALEs)—generally employers with 50 or more full-time and full-time equivalent employees in the prior calendar year— must report offers of health coverage to the IRS and provide statements to employees using the following forms:

• Form 1095-C – Provided to full-time employees and filed with the IRS
• Form 1094-C – Transmittal form summarizing the employer’s reporting

These forms are used by the IRS to determine whether the employer complied with the ACA employer shared responsibility provisions and whether employees may be eligible for premium tax credits through the Marketplace.

Additionally, all employer-sponsors of self-insured health coverage, regardless of size, must report months of enrollment in coverage to the IRS and provide statements to covered individuals using the following forms:

• Form 1095-B – Provided to covered individuals and filed with the IRS
• Form 1094-B – Transmittal form summarizing the employer’s reporting

Under IRS regulations finalized in recent years, employers that file 10 or more information returns in aggregate during the year must submit those forms electronically. This threshold applies to the total number of information returns filed with the IRS, including forms such as:

• Forms W-2
• Forms 1099
• ACA reporting forms (Forms 1095-C and 1094-C)

Because the threshold is calculated in aggregate, most employers—including those with relatively small workforces—will now be required to file ACA forms electronically.