Under ACA, ALEs and other employers with self-funded plans must report information about offers of coverage to individuals and to the IRS.
There are four IRS forms: 1094-B, 1095-B, 1094-C and 1095-C. The C series of forms are used by ALEs to report information about full-time employees and covered individuals. The B series of forms are used by small employers with self-funded health coverage (as plan sponsor) and by insurance companies to report information about covered individuals. The B series of forms may also be used by larger plan sponsors (acting, in a way, as an insurance company) to report coverage information.
- ALE with Fully Insured Coverage- Employer sends Form 1095-C to its full-time employees and transmits information to the IRS using Form 1094-C. The insurance company sends Form 1095-B to covered individuals.
- ALE with Self-Insured Coverage- Employer sends Form 1095-C to full-time employees and to covered individuals. Employer transmits information to IRS using Form 1094-C.
- Small Employer with Fully Insured Coverage- Insurance company takes care of all reporting using Forms 1094-B and 1095-B.
- Small Employer with Self-Funded Coverage- Employer sends Form 1095-B to covered individuals and transmits information to the IRS using Form 1094-B.
*Special Note- Some large plan sponsors, such as Archdioceses and other unique coverage offerers, are acting (in a way) as an insurance company and sending Form 1095-B to employees covered under their plans.
Reporting was required for the first time in 2016 for the 2015 calendar year. The Form 1095-B/C must be furnished to individuals by January 31 each year.
Form 1094-B/C must be filed by February 28 (if by paper) or by March 31 (if e- file) each year. There were delayed filing timeframes in 2016 for the 2015 filing year.
