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2016 ACA Reporting Deadline Approaches

The deadline for mandatory employer reporting requirements under the ACA is rapidly approaching.


Applicable large employers (ALEs) and employers providing self-insured health coverage, will be required to comply with reporting requirements by the official deadline of Monday, February 28.

Although House Speaker Paul Ryan (R-Wis.) recently said to that legislation to repeal and replace the Affordable Care Act will be introduced in the House on February 27 (when Congress comes back from its break), it not be in time to impact the 2016 reporting deadline. And while one of President’s first acts in office was to issue an executive order directing government agencies to scale back elements of the law, it didn’t give any specifics on which parts of the law it was intended to target.

In the interim until further legislation is passed or executive action is taken, the current IRS reporting deadlines stand, which means that employers and providers choosing to file via paper submission have less than a week to do so. (The deadline for e-file submissions is still March 31.)

If you still need a little guidance on ACA reporting requirements, we prepared a bit of a refresher for you below.

The different ACA reporting forms

In response to the Affordable Care Act (ACA), the IRS established Internal Revenue Code Sections 6055 and 6056, which outline the information applicable entities (health insurance providers and employers) must report on each year, and created forms for applicable entities to use to report this information.

There are five forms required for 6055 and 6056 reporting: Form 1094-B, Form 1094-C, Form 1095-A, Form 1095-B and Form 1095-C. The name of each form is designed to indicate who receives the form, and who the forms are coming from. Each form name follows the same naming formula: Form 109X – Y, in which the “X” indicates the type of form and who receives it, and the “Y” indicates who the form is coming from.

  • Summary Pages (1094 – Y) & Individual Pages (1095 – Y)
    An easy way to think about the difference between 1094 and 1095 forms is to relate them to the W-3 and W-2 forms you’re already filling out each year, in which the 1094 form is like the W-3 – it is a summary cover sheet of all of the information, and the 1095 form is like the W-2 – it is a detailed form about each covered individual.
  • Marketplace, Carrier & Employer Pages (109X – A, 1094X – B & 109X – C)
    This part of the form name indicates who is responsible for completing and submitting the forms: either the marketplace, the carrier or the employer. (Please note that this breakdown applies only to employers in fully insured arrangements – employers who are self-funded will have different rules.)

Not entirely clear on what you’re supposed to file?

Head on over to the Resources section of the G&A Partners site to view our infographic: “The ACA IRS Reporting Guide.”
ACA Reporting Guide

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