All About ACA IRS Reporting Requirements

When it comes to complying with the new health care regulations, nothing is simple. Even knowing what to call the health care reform law – Affordable Care Act, Obamacare, PPACA – can be confusing. With so many complex requirements and exceptions, health care reform compliance is enough to give any business owner a headache.

Before you start reaching for the aspirin, however, take a moment to read over this brief explanation of each of the IRS forms associated with the health care law.

Internal Revenue Code Sections 6055 & 6056

Let’s start at the beginning. 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.

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 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.

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.

Decoding the ACA IRS forms

There are really only 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. To help you decode each form, we’ve created an easy chart for you to use:

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.)

Knowing which forms to use is just the first step in complying with the Affordable Care Act’s reporting requirements. Fill out the form on the right and we’ll send you our ACA Reporting Quick Reference Guide, which outlines the reporting responsibilities and deadlines for each of these five forms.