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).

Q:  Does my organization have to provide a 1095-C form to terminated employees? 

The answer depends on whether or not you’re an Applicable Large Employer (ALE), and whether you’re self-insured or not.

If your organization is an ALE, you must complete a 1095-C form for any employee who was full-time for any month during 2015, even if they are no longer working for your organization or if you don’t offer a health plan.

The grids below provide guidelines on required company reporting for former employees:

Former Employee Situation Self-Insured ALE
Form 1095-C
Self-Insured, Non-ALE
Form 1095-B
Fully-insured, ALE (Report Full-time Employees only)

Form 1095-C

Fully-insured, Non-ALE
Active full-time employee who accepted coverage and termed in 2015 Yes

 

Yes Yes

(ALE report*)

No
(insurer completes)
Active full-time employee who declined coverage, or was not offered coverage and termed in 2015 Yes No Yes
(ALE report*)
No
Active part-time employee who accepted coverage and termed in 2015 Yes Yes No No

(insurer completes)

Active part-time employee who was not covered under the plan and termed in 2015 No No No No
COBRA: Employee active for part of 2015, then experienced COBRA-qualifying event Yes Yes Yes

(ALE report*)

No

(insurer completes)

COBRA: COBRA coverage provided during 2015, but employee was not an active employee at any time in 2015

 

Yes

(report coverage provided)

Yes

(report coverage provided)

No

(insurer completes)

No

(insurer completes)

Retiree Medical: Employee retired during 2015, and offered organization’s Retiree Medical coverage Yes Yes Yes

(ALE report*)

No

(insurer completes)

Retiree Medical: Retiree covered during 2015 under retiree medical, but was not an active employee at any time in 2015 Yes
(report coverage provided)
Yes
(report coverage provided)
No

(insurer completes)

No

(insurer completes)

*ALE Report is required under IRC §6056 using forms 1095-C and 1094-C

For non-employees who are covered under your health plan, you may use either forms 1095-C and 1094-C, or forms 1095-B and 1094-B to report their coverage.

  Self-Insured ALE Self-Insured Non-ALE Fully-insured, ALE Fully-insured, Non-ALE
Non-Employee Participant: For example, Directors and others who are not employees, but are covered under the organization’s plan Yes
(report coverage provided)
Yes
(report coverage provided)
No

(insurer completes)

No

(insurer completes)