ACA Form Requirements

By now, employers should have their measurement periods and stability periods set and be well on their way to collecting the data needed to complete the reporting required under the ACA. 

For fully-insured small group plans, the carrier will complete Forms 1094-B and 1095-B. Small groups that sponsor a self-funded group health plan will need to complete these forms as well. Small group, fully-insured plans with a self-funded HRA will need to complete Forms 1094-B and 1095-B for the HRA. 


All Applicable Large Employers (ALEs) will need to complete Forms 1094-C and 1095-C; this is any group with 50 or more full time equivalent employees. ALE’s who sponsor a fully insured plan will NOT need to complete Part III of Form 1095-C. ALE’s who sponsor self-funded group health plans WILL need to complete Part III of Form 1095-C. 


The reporting is done on a calendar year basis. Regardless of plan year or any transitional relief, all ALEs will need to complete the 2015 reporting. All Form 1095s need to be provided to individuals on or before January 31 of each year (or the next business day if it falls on a weekend or Federal holiday). 


Entities filing 250 or more 1095-Cs must file their returns electronically. Keep in mind when determining how many Form 1095-Cs you will have that you must issue one to anyone who was a full-time employee during the year, even if only for a month. As with other transmittals of information returns the transmittal should be filed at the same time in the form of a Form 1094-B or 1094-C. Employers with fewer than 250 returns are also encouraged to still file electronically, but may opt to make the returns in paper form. They be filed with the IRS annually, no later than February 28 (March 31 if filed electronically) for the previous year. For example, the first returns to be filed will be for the 2015 calendar year. These will need to be filed by March 1, 2016 (February 28, 2016 is a Sunday), or March 31, 2016 if filed electronically.


The IRS has provided for a single option for filing the forms electronically, referred to as the ACA AIR Program. In order to file electronically, employers will need someone fluent in software development/coding in order to file. There is also a process that needs to be started now in order to verify correct electronic filing. This is a lengthy process that employers will not be able to complete without a skilled software developer. It is not a process that Assurance will be able to assist you with. 


If you are required to file electronically or are not required to, but are hoping to file electronically, the deadline for finding a vendor to assist is rapidly approaching. We will not be able to assist in completing or filing the forms, however, we will be happy to talk through the information needed on the forms and answer any questions you may have about them.

Contact your Assurance representative if you have not yet determined your method of filing.