Employer Reporting Requirements - Final Forms and Supporting Documents Released
(Posted on 02/17/15)
The IRS has released the final forms and instructions for the employer and insurer reporting requirements. These reports will be due in early 2016 reporting on coverage during the 2015 calendar year. Both insurers and applicable large employers can now ensure that their systems are set up to properly record this information during 2015 so they are prepared to file the reports in 2016.
Employer Reporting Requirements
- An Applicable Large Employer (ALE) is any employer with 50 or more full-time equivalents. It is important to note that ALEs must report even if they are: insured in the small group market, uninsured, or self-insured. Also, ALEs must report even if they are taking advantage of a safe harbor and not liable for employer mandate penalties in 2015. To better understand who is subject to the mandate and the safe harbors that are available, see the Questions and Answers on

Employer Shared Responsibility Provisions Under the Affordable Care Act link below.
-ALEs are required to file 1095-C reports on each full-time employee.
-The 1095-Cs are filed by sending a copy to the IRS and a copy to each individual full-time employee.
-These reports are used to administer the employer mandate and to reconcile subsidies.
-Copies of the final forms, instructions and a new informational flyer from the IRS geared at explaining the new requirements to employers are linked below.

Insurer Reporting Requirements
-All providers of coverage (i.e insurers for fully insured plans, government agencies, and employers for self-funded plans) must file a 1095-B report on each enrolled individual.
-The 1095-Bs are filed by sending a copy to the IRS and a copy to each contract holder. The forms are sent to the contract holder and will list each enrolled dependent.
-These reports will be used to administer the individual mandate.
-Copies of the final forms, instructions and publications from the IRS are linked below.

Marketplace Reporting Requirements
-The marketplace will be filing 1095-A reports in 2015 reporting on coverage obtained through the marketplace in 2014. These are the only reports that will be done on the 2014 calendar year.

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