Affordable Care Act (ACA) forms 1095 and 1094

The Patient Protection and Affordable Care Act (PPACA), also known as the Affordable Care Act (ACA), is a United States federal statute signed into law on March 23, 2010. The ACA contains comprehensive health insurance reforms and tax provisions that affect almost everyone. These provisions contain changes that include benefits and responsibilities for organizations and employers.

What is ACA Reporting?

The Affordable Care Act added Section 6055 and 6056 to the Internal Revenue Code, which requires every provider of Minimum Essential Coverage (MEC), including Applicable Large Employers (ALEs) and certain government entities, to file information returns with the IRS and provide statements to their recipients or Full-time Employees about offered health insurance coverage and health care enrollment.

Who needs to File ACA Reports?

Applicable Large Employers (ALE) and Marketplace Insurers offer Minimum Essential Coverage (MEC) to Individuals, regardless of whether they are a tax-exempt or government entity. ALEs and Insurers report Form 1095-B and Form 1094-B to the IRS. ALEs offer Minimum Essential Coverage (MEC) to their Full-time Employees by reporting Form 1095-C and Form 1094-C to the IRS.

ACA Forms Due Dates for Tax Year 2016




Form W-2 recipients

Provide ACA Forms 1095-B & 1095-C to all employees/enrollees




Paper Filing

IRS paper filing deadline for ACA Forms 1094-B, 1094-C,
1095-B, & 1095-C





IRS e-filing deadline for ACA Forms
1095-B & 1095-C

Filing ACA Forms

Forms 1094 and 1095 report information on your Offer of Coverage and the Provided Coverage in a calendar year. Form 1094-B is for insurers to file to the IRS; it is filed with Form 1095-B, which is distributed to each enrollee. Form 1094-C is for Applicable Large Employers (those with 50+ Full-time Equivalent Employees) to file to the IRS; it is filed with Form 1095-C, which is distributed to each employee.

Form 1095-B for Insurers

Form 1095-B is used to report certain information to the IRS and to taxpayers about individuals who are covered by Minimum Essential Coverage. Insurers and self-funded plans that provide Minimum Essential Coverage to an individual during a calendar year must file these information returns. However, it is not necessary to report coverage under the Children’s Health Insurance Program, Medicaid, Medicare, or the Basic Health Program. Filers will use Form 1094-B (transmittal to the IRS) to submit Forms 1095-B (returns) to their enrollees.

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Form 1095-C for Employers

Applicable Large Employers (ALEs), which are employers with 50 or more full-time employees in the previous year, use Forms 1094-C and 1095-C to report information to the IRS on coverage provided, including when and to whom the coverage was offered. Employers that offer employer-sponsored self-insured coverage must also use Form 1095-C to report this information. An ALE member must file one or more copies of Form 1094-C (including one designated as the Authoritative Transmittal) and must file Form 1095-C for each employee. Generally, the employer is required to furnish a copy of Form 1095-C to the employee.

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What information about an individual needs to be reported on the information return?

Employers need to be tracking all of the data they will need to report in January on a monthly basis, for each of his employee. This includes:

  • Total employee count & Full time employee count
  • Employee ID, name, and address
  • Health coverage offered
  • Employee share of the monthly premium (for lowest-cost self-only minimum coverage)
  • Months the employee was enrolled in employer coverage
  • Affordability safe harbor information
  • If self-insured, information about covered individuals in plan

Frequently Asked Questions

Section 6055 requires that the names, addresses, and social security numbers for all covered individuals, including spouses and dependents, be reported to the IRS. The report must also include the month(s) in which the individual was enrolled in coverage for at least one day. This information allows the IRS to verify that a particular individual has the Minimum Essential Coverage (MEC). In the case of fully insured group health coverage, issuers are also required to report the employer's name, address, and Employer Identification Number (EIN).

Section 6055 reporting requires groups that provide Minimum Essential Coverage (MEC), such as insurers and self-funded employers, to file an informational return to the IRS. This provides basic identifying information about persons that have been provided MEC (e.g., name, address, and ID) and the month(s) in which the person was covered for at least one day.

Internal Revenue Code Section 6055 requires insurers, self-funded employers, and other providers of MEC to file an annual report to the IRS for purposes of reporting individuals covered by MEC. This requirement applies regardless of plan size.

Insurers, self-funded plans, and other providers of MEC must file Form 1094-B and Form 1095-B to the IRS. These reports advise the IRS about whether or not the individual was covered by MEC, and are required regardless of plan size.

Self-funded plan sponsors subject to employer shared responsibility requirements can accomplish MEC reporting obligations by completing Form 1094-C and Parts I, II, and III of Form 1095-C. Self-funded plans that are not subject to shared responsibility requirements complete their obligation with Form 1094-B and 1095-B.

If the health coverage provided is insured, the insurer completes the MEC reporting with Forms 1094-B and 1095-B. The insurer is then required to provide 1095-B forms to the insureds listed in the corresponding 1094-B.

If the health coverage is obtained through the marketplace, the reporting is accomplished by filing Form 1095-A.

Reports can be submitted to the IRS in either paper format by May 31st, or electronic format by June 30th. Groups that file 250 or more returns will be required to file electronically.
Under Section 6056, non-ALE employers are not required to file Form 1094-C and/or Form 1095-C. If you're not considered an Applicable Large Employer, you are still required to complete Form 1094-B and Form 1095-B to the IRS and employee transmittal.
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