Affordable Care Act Reporting: Forms 1094 and 1095

The reporting requirements released by the IRS are enough to scramble anyone’s mind, and this certainly applies to Forms 1094 and 1095. While there have been many changes with healthcare reform, the large group mandate and associated penalties still apply. Blue Chip Benefits has tried to simplify this for employers, below. Note, March 2nd is the due date for submitting forms to employees.

The IRS uses forms 1094 and 1095 to make sure each large employer (a) offers minimal essential coverage and (b) that the coverage is affordable.

  • Individuals on State health exchanges receive the 1095-A form from the Exchange
  • Small employers with less than 50 full time employees (FTE) that do not offer health insurance or offer a fully insured medical plan –  there is nothing employers need to do as the insurance carrier submits all documentation to the IRS and provides enrolled employees with the 1095-B
  • Small and large groups with fully insured health plans— the insurance carriers send the 1095-B to all members
  • Fully insured employers with 50+ FTE must complete Form 1095-C, plus the IRS transmittal Form 1094-C, while your insurance carrier (Blue Cross Blue Shield, United Healthcare, etc.) will issue a separate 1095-B to enrolled employees
  • Self-insured small group employers with less than 50 FTE need to send Form 1094-B to the IRS along with copies of the 1095-B, with the original 1095-B going to employees
  • Self-insured large group employers with more than 50 FTE need to send the 1095-C to all employees whether they are enrolled or not in medical coverage, as well as send the 1094-C IRS transmittal form to the IRS

The IRS uses Forms 1094 and 1095 to make sure each large employer (a) offered minimal essential coverage and (b) that the coverage was affordable. Failure to do so could result in a penalty to the employer. Form 1095-C provides the IRS with the necessary data to evaluate this. In the case of a fully insured large employer, employees should receive two forms – 1095-B from the insurance company and 1095-C from the employer. If your company offers a self-insured plan, employees should only receive one form from the employer, Form 1095-C.

The date for supplying employees with Form 1095 is March 2nd. The date for submitting Forms to the IRS are February 28 if mailing and March 31st if submitting electronically.

Please see the following flow chart that will hopefully make it easier for companies to determine responsibilities.

IRS Form 1095 Taxpayer Coverage Scenario

For more information, contact Maureen at or (888) 225-8244, x701.

Scroll to Top