Required ACA Reporting


The IRS recently announced that it has extended the 2018 deadline for insurers, self-insured employers, applicable large employers (ALE), and other coverage providers to provide Forms 1095-B and 1095-C to individuals who received health insurance coverage in 2017.

While the recent tax reform legislation eliminates the Affordable Care Act (ACA) mandate for individuals purchasing health insurance for months beginning after December 31, 2018, the requirements for ACA Reporting by employers have not changed. And it’s important to know that the individual mandate is in effect through income tax filing for the 2018 calendar year.

Under the Individual Shared Responsibility provision of the Affordable Care Act (ACA), a tax penalty is imposed on individuals that do not maintain coverage under a health plan that provides minimum essential coverage (MEC). The reporting requirements of MEC are declared in Internal Revenue Code (IRC) Section 6055.


Under the Individual Shared Responsibility provision of the Affordable Care Act (ACA), a tax penalty is imposed on individuals that do not maintain coverage under a health plan that provides minimum essential coverage (MEC). The reporting requirements of MEC are declared in Internal Revenue Code (IRC) Section 6055.

6055 Reporting on Form 1095-B

Provided by Insurer for insured medical plan; by employer for a self-insured medical plan

Provided to each covered “responsible individual” (e.g., employee, COBRA QB, retiree)

Provided by March 2, 2018 for coverage in prior calendar year

Transmitted with employer’s Form 1094-B to IRS by February 28, 2018 (April 2, 2018 if filed electronically)

Some HRAs are subject to being reported



The Play-or-Pay provision of the ACA can impose excise tax penalties on applicable large employers (ALEs) not offering their group medical plan to enough full time employees and dependents or the coverage offered is not of minimum value and affordable. The ALE’s reporting requirements are declared in IRC Section 6056.


The Play-or-Pay provision of the ACA can impose excise tax penalties on applicable large employers (ALEs) not offering their group medical plan to enough full time employees and dependents or the coverage offered is not of minimum value and affordable. The ALE’s reporting requirements are declared in IRC Section 6056.

6056 Reporting on Form 1095-C

Provided by applicable large employer (ALE)

Provided to each full time employee

Provided by March 2, 2018 for coverage offered in prior calendar year

Transmitted with employer’s Form 1094-C to IRS by February 28, 2018 (April 2, 2018 if filed electronically)

Some HRAs are subject to being reported


For downloads and more information on the Affordable Care Act, be sure to visit Keeping Up with Health Care Reform and Compliance Buzz.