ACA Reporting Requirements

Certain Group Health Plans Required to File ACA Section 6055 & 6056 Reporting

Group health plan administrators are reminded that Affordable Care Act (ACA) reporting under Section 6055 and Section 6056 must be filed with the Internal Revenue Service (IRS) by February 28, 2022 (or March 31, 2022 if filing electronically) and individual statements must be provided to individuals by March 2, 2022.

Who Must File?

Applicable Large Employers (ALEs), generally employers with 50 or more full-time employees including full-time equivalents in the previous calendar year, are required to complete ACA Section 6056 reporting requirements, generally using Forms 1094-C and 1095-C to report coverage information.

Also, employers with group health plans that were self-insured or level-funded (combination of fully insured and self-insured) in the previous calendar year are required to complete ACA reporting requirements, no matter the number of full-time employees.

How To Prepare + File

Depending on your group health plan’s carrier your plan’s ACA reporting requirements may be prepared and/or filed by the carrier. The IRS encourages employers to file returns electronically using the AIR filing system. Paper filings are acceptable in some situations following specific requirements – employers with fewer than 250 individual statements may submit paper filings following specific requirements. In addition, employers must generally distribute individual statements to employees. For more information, please reference the following resources:

• 2021 Forms 1094-C and 1095-C (and instructions) to be used by applicable large employers (ALEs) to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured or level-funded plans.
• 2021 Forms 1094-B and 1095-B (and instructions) to be used by entities reporting under Section 6055, including self-insured and level-funded plan sponsors that are not ALEs.