Updated IRS Reporting Requirements

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Important Update: The IRS has issued guidelines that will extend the deadline to distribute 1095-C to employees from January 31, 2018 to March 2, 2018. Note – this extension does not extend the deadline to file the 1094-C and 1095-C to the IRS.


As a reminder, we are entering our 3rd year of the ACA Reporting Requirements. Employers will need to evaluate the most efficient method of collecting data about their employees and their health plan.


Employers will be responsible for reporting this data to the IRS as well as their eligible employees.


What You Need To Know

  • The purpose of this reporting is to help the IRS determine if you as an employer are complying with the rules and regulations of the Affordable Care Act – specifically the employer mandate.
  • These reporting requirements will need to be filed on an annual basis. The 2017 Reporting year is the 3rd year of this reporting. The data collected for these reports will need to occur on a monthly basis in order to stay compliant.
  • It is important to review these requirements now so that you’re prepared to collect the necessary data beginning in January 2018.


Who Has To Report

  • Applicable Large Employers who are subject to the employer shared responsibility provisions of the Affordable Care Act will be required to collect and report specific data to the IRS.
  • An applicable large employer is defined as any employer who had 50 or more full-time equivalent employees in the previous calendar year.
  • Fully Insured Employers will be responsible for Part I and Part II on IRS Form 1095-C
  • Self Insured Employers will be responsible for completing IRS Form 1094-C


What Has To Be Reported

  • Employer will be responsible for submitting the appropriate forms (1094-C or 1095-C) to both the IRS and employees that are covered under the plan.


Third Party Reporting Services

  • We have created partnerships with a number of Third Party Reporting providers that can help fulfill your reporting requirements.
  • Contact your dedicated Account Manager if you need assistance with the ACA Reporting Requirements

Due Date

Forms to employees: March 2, 2018

Forms to IRS: Feb 28, 2018 – if filed via paper, March 31, 2018 if filed electronically


For more information:


IRS website with FAQs on IRS reporting

Link to the 1095-C reporting form

Link to the 1094-C reporting form

1094-C and 1095-C Instructions

Link to IRS Notice extending employee distribution deadline

IRS Reporting