Large employers with 50 or more employees, and smaller employers with self-funded health plans, should be prepared to report health coverage and offer of coverage information to individuals and the IRS in early 2016.
The first ACA report, due January 31, 2015, is a form provided to full-time employees, full-time equivalent employees and individuals covered under the health plan.
Individual reporting is accomplished through Form 1095. A large employer reports using Form 1095-C. A small employer with self-funded health coverage reports using Form 1095-B. Insurance companies use Form 1095-B to report coverage information to individuals. Individuals use the 1095 they receive to document their health coverage or offer of coverage to avoid the individual mandate penalty.
A reporting entity must send a transmittal (Form 1094) to the IRS on or before February 28, 2016 (March 31 if filed electronically). The 1094 transmittal is used by the employer to document their pay or play health care reform compliance. It includes a copy of all Form 1095-Cs sent to individuals.
Employers should have their ACA reporting strategy prepared in order to meet looming deadlines.