Small employers (those with fewer than 50 FTEs) with a self-insured health plan must complete and file Forms 1095-B (Health Coverage) and 1094-B (accompanying transmittal form) with the IRS, as well as provide employees—specifically, those who are taxpayers responsible for showing they had health coverage during the year—with a copy of Form 1095-B. The 1095-Bs will be provided by insurance companies for fully insured plans. Small employers with fewer than 50 FTEs also will be required to file Forms 1095-C and 1094-C if they are members of a controlled or affiliated service group that collectively has at least 50 FTEs.
Applicable Large Employers (ALEs) with at least 50 FTEs must complete and file Forms 1095-C (Employer-Provided Health Insurance Offer and Coverage) and 1094-C (accompanying transmittal form), and provide each full-time employee with a copy of Form 1095-C. ALEs must prepare a Form 1095-C for each full-time employee, regardless of whether the employee is participating in an employer-sponsored group health plan, and for each part-time who is enrolled in the employer’s self-insured health plan. ALEs need not prepare Form 1095-C for part-time employees who are not enrolled in the plan.
Individuals who receive health coverage through “the Marketplace,” meaning an ACA federal or state health insurance exchange, will receive Form 1095-A (Health Insurance Marketplace Statement) from the Marketplace to allow them to report their premium tax credit and to reconcile that credit on their tax returns. ALEs will be exposed to nondeductible taxes for every employee who receives a tax credit subsidy to purchase health care on a public exchange.
For the 2015 plan year, forms that must be filed with the IRS are due no later than Feb. 29, 2016 (or March 31, 2016, if filed electronically). But employee copies of Forms 1095-B and 1095-C, if required, must be provided to employees annually by Jan. 31, 2016.
