ACA Reporting Advisor

Welcome to MSEC’s weekly ACA FAQ on reporting. While details on how to complete IRS forms 1094 and 1095 (such as what codes to use on specific lines of the form) will not be covered, general questions on reporting requirements will be answered. For detailed information on form completion, contact your broker, tax advisor, payroll company, or insurance carrier. If you have a general ACA reporting question, email it to aca@msec.org.  The most commonly asked questions will be answered in this forum. In addition, the Health Care Reform Learning Zone, found on the MSEC website (msec.org), is a rich source of information about the Affordable Care Act (ACA).

What information do I need to gather for each report?

The Minimum Essential Coverage (MEC) report (§6055) includes:

  • The name, address, and EIN of the employer sponsoring the plan;
  • The name, address, and taxpayer ID number (generally the social security number (SSN)) of the employee or former employee;
  • The name and SSN of each other covered individual;
  • The months during which each individual was enrolled in coverage during the calendar year for at least one day; and
  • Any other information required by the IRS.

In addition, insurers of fully insured plans must report:

  • Information requested by the IRS to administer the tax credit for eligible small employers;
  • Where coverage was enrolled through a SHOP exchange and the SHOPs unique identifier.

The Applicable Large Employer (ALE) report (§6056) includes:

Employer’s name, the date, and the employer’s EIN and the calendar year for which the information is reported;

  • The name and telephone number of a contact person;
  • A certification as to whether the employer offered full-time employees (and their dependents) the opportunity to enroll in minimum essential coverage under the plan by calendar month;
  • The number of full-time employees for each calendar month during the calendar year, by calendar month;
  • For each full-time employee, the months during the calendar year for which minimum essential coverage under the plan was available;
  • For each full-time employee, the employee’s share of the lowest cost monthly premium for self-only coverage providing minimum value offered to that fulltime employee under the plan, by calendar month; and
  • The name, address, and taxpayer identification number (SSN) of each full-time employee during the calendar year and the months, if any, during which the employee was covered under the plan.

The return will also include indicator codes to report the following information:

  • Whether the coverage offered to full-time employees and their dependents provides minimum value and whether the employee had the opportunity to enroll his or her spouse in the coverage;
  • The total number of employees, by calendar month;
  • Whether an employee’s effective date of coverage was affected by a permissible waiting period;
  • Whether there were no employees during a particular month;
  • Whether the employer is part of a controlled group, and, if applicable, the name and EIN of each employer member of the controlled group;
  • If an appropriately designated person is reporting on your behalf that is a governmental unit for purposes of §6056, the name, address, and identification number of the appropriately designated person.

Q:  What reporting forms do I need to do? 

A:  The table below shows the different reporting requirements based the health plan’s funding method and the organization’s size.

Health Plan Funding and Employer Size Applicable Large Employer (ALE) Report (IRC Sec 6056) Minimum Essential Coverage (MEC) Report (IRC Sec 6055)
Fully-Insured—ALE* Employer completes and submits:

·       Form 1095-C (Parts I & II) to each full-time employee by Jan 31, 2016; and

·       Form 1094-C (transmittal) with copies of all 1095-C’s to IRS by Feb 28 (paper) or March 31 (electronic)

Insurer completes and submits:

·       Form 1095-B to each employee by Jan 31, 2016; and

·       Form 1094-B (transmittal) with copies of all 1095-B’s to IRS by Feb 28 (paper) or March 31 (electronic)

Fully-Insured—Non-ALE Not required Insurer completes and submits:

·       Form 1095-B to each employee by Jan 31, 2016; and

·       Form 1094-B (transmittal) with copies of all 1095-B’s to IRS by Feb 28 (paper) or March 31 (electronic)

Self-Insured—ALE*

 

Employer combines ALE and MEC reporting on the same forms and submits:

·       Form 1095-C (all Parts) to each covered employee by Jan 31, 2016; and

·       Form 1094-C (transmittal) with copies of all 1095-C’s to IRS by Feb 28 (paper) or March 31 (electronic)

Self-Insured—Non-ALE Not required Employer completes and submits:

·       Form 1095-B to each covered individual by Jan 31, 2016; and

·       Form 1094-B (transmittal) with copies of all 1095-B’s to IRS by Feb 28 (paper) or March 31 (electronic)

Not offering health coverage—ALE Employer completes and submits:

·       Form 1095-C (Parts I & II) to each full-time employee by Jan 31, 2016; and

Form 1094-C (transmittal) with copies of all 1095-C’s to IRS by Feb 28 (paper) or March 31 (electronic)

Not required
Not offering health coverage—Non-ALE Not required Not required
*ALE is an employer with 50 or more full time plus full-time equivalent employees

Employers participating in a multiple employer plan should check with their plan administrator to determine their filing requirements.

Forms can be found on the IRS website at:

“C” Forms:

Form 1095-C:  https://www.irs.gov/pub/irs-prior/f1095c–2015.pdf

Forms 1094-C: https://www.irs.gov/pub/irs-prior/f1094c–2015.pdf

Instructions for 1094-C/1095-C: https://www.irs.gov/pub/irs-prior/i109495c–2015.pdf

“B” Forms:

Form 1095-B:  https://www.irs.gov/pub/irs-prior/f1095b–2015.pdf

Form 1094-B:  https://www.irs.gov/pub/irs-prior/f1094b–2015.pdf

Instructions for 1094-B/1095-B:  https://www.irs.gov/pub/irs-prior/i109495b–2015.pdf