peo company

Who Reports What, To Whom, And When? | ACA Reporting Requirements

Preparing For The Affordable Care Act In 2016

When it comes to the Affordable Care Act, many employers are suffering from information overload. Despite an abundance of information available, employers often find themselves overwhelmed by the sheer amount of information they need to wade through in order to figure out what forms they need to complete and file in order to comply with the ACA’s IRS reporting requirements. And, even after reading dozens of articles, many employers are still as confused as ever as to what their responsibilities are.

In order to help demystify ACA reporting, we’ve broken down these complex requirements into a simplified guide that outlines what each form is, who is responsible for completing it, who receives the form upon completion, and when the form is due.

IRC Sections 6055 & 6056

Let’s start at the beginning. You may have heard the terms “6055” and “6056” associated with ACA reporting. A common phrase our experts hear is “When do I have to submit that 6056 form?” However, it’s important to note that 6055 and 6056 are not the names of actual IRS forms, but the names of the Internal Revenue Code (IRC) sections that outline the specific requirements for health insurance providers and employers in order to monitor compliance with all applicable provisions of the health care law. The IRS has created specific forms for employers to use to report the information required under each code section. 

IRC Section 6055

IRC Section 6055 requires providers of minimum essential coverage, regardless of group size, to report certain information regarding the coverage provided on an annual basis. For the purposes of employer reporting, minimum essential coverage is defined as eligible employer-sponsored coverage. It is important to note, however, that employers providing coverage through a fully insured arrangement will not be required to report as a provider of health coverage under Section 6055. In these cases, the health insurance issuer or carrier will be responsible for reporting coverage.

IRC Section 6056

IRC Section 6056 requires applicable large employers (ALEs), defined as those with 50 or more full-time or full-time equivalent employees, to provide certain information regarding the health coverage the employer did or did not offer to each of its full-time employees on an annual basis.

Decoding the IRS forms

There are really only five forms required for 6055 and 6056 reporting. 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 109XY, in which the “X” indicates the type of form and who receives it, and the “Y” indicates who the form is coming from. To help you decode each form, we’ve created an easy chart for you to use:

Decoding_ACA_IRS_Forms

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.)

Now that you have a bit of a greater understanding of the overall reporting requirements, it’s time to take a deeper dive into each form.

Form 1094-C:

Name: Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
Purpose: Enforce employer mandate; summary of 1095-C forms
Who completes it?: Employer members of ALEs
How is it filed?: Employers with 250+ employees are required to submit electronically; employers with fewer than 250 employees may either submit paper forms via mail or submit electronically
Who receives it?: IRS
When is it due?:Paper forms must be submitted to the IRS on or before the last day of February; electronic submissions are due on or before the last day of March.

Form 1095-C:

Name: Employer-Provided Health Insurance Offer and Coverage
Purpose: Enforce employer mandate; disclose employer offer of MEC coverage
Who completes it?: Employer members of ALEs
How is it filed?: Employers with 250+ employees are required to submit electronically; employers with fewer than 250 employees may either submit paper forms via mail or submit electronically
Who receives it?: Employees (covered or not) & IRS
When is it due?: Forms must be made available to employees on or before the last day of January. Paper forms must be submitted to the IRS on or before the last day of February; electronic submissions are due on or before the last day of March.

Form 1094-B:

Name: Transmittal of Health Coverage and Information Returns
Purpose: Provide proof of MEC coverage for enforcement of individual mandate; Summary of 1095-B forms
Who completes it?: Carrier or self-funded plan sponsor
How is it filed?: Employers with 250+ employees are required to submit electronically; employers with fewer than 250 employees may either submit paper forms via mail or submit electronically
Who receives it?: IRS
When is it due?: Paper forms must be submitted to the IRS on or before the last day of February; electronic submissions are due on or before the last day of March.

Form 1095-B:

Name: Health Coverage
Purpose: Provide proof of MEC coverage for enforcement of individual mandate
Who completes it?: Carrier or self-funded plan sponsor
How is it filed?: Employers with 250+ employees are required to submit electronically; employers with fewer than 250 employees may either submit paper forms via mail or submit electronically
Who receives it?: Covered employees, covered non-employees & IRS
When is it due?: Forms must be made available to employees on or before the last day of January. Paper forms must be submitted to the IRS on or before the last day of February; electronic submissions are due on or before the last day of March.

Form 1095-A:

Name: Health Insurance Marketplace Statement
Purpose: Provide proof of coverage on the exchange
Who completes it?: Exchange carrier
How is it filed?: Electronically
Who receives it?: Covered individuals
When is it due?: Forms must be made available to covered individuals on or before the last day of January.

ACA IRS Reporting Requirements - Form Overview

Click here to download the ACA IRS Form Overview Document

Are you overwhelmed by the sheer amount of information necessary to fill out these forms? You’re not alone. Most organizations simply aren’t capable of easily capturing this data and generating the necessary reports. Learn how G&A Partners can simplify the employer reporting process with our ACA compliance support services by calling 1-866-634-6713 to speak to our health care experts or visiting https://www.gnapartners.com/contact-us/ to schedule a free business consultation.

This article is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.

Comments are closed.

Let's talk

Sales Questions

(866) 927-6203

Contact a Business Advisor
Customer Care

(866) 927-6203

Contact Customer Care