Highlights

PURPOSE OF §6056 REPORTING

  • This additional reporting is intended to promote transparency in health plan coverage and costs.

  • It will also provide the government with information to administer the employer shared responsibility rules, which imposes penalties on ALEs that do not offer affordable, minimum value coverage to their full-time employees (and dependents).

FORMS USED FOR REPORTING

ALEs that are reporting under Section 6056 will use:

  • Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return; and
  • Form 1095-C, Employer-Provided Health Insurance Offer and Coverage.

Employer Reporting of Health Coverage—Code Section 6056

The Affordable Care Act (ACA) created reporting requirements in Internal Revenue Code (Code) Section 6056. Under these rules, applicable large employers (ALEs) subject to the ACA’s employer shared responsibility rules must provide information to the Internal Revenue Service (IRS) about the health coverage they offered to their full-time employees. Related statements must also be provided to each of the ALE’s full-time employees.

Reporting was first required in early 2016 for calendar year 2015. For the 2018 calendar year:

  • Returns must be filed no later than Feb. 28, 2019, or April 1, 2019, if filed electronically; and
  • Individual statements must be furnished by March 4, 2019.

This ACA Overview describes the Section 6056 reporting requirements.

Links and Resources

FILING REQUIREMENTS—REQUIRED FORMS

Under Section 6056, each ALE is required to file all of the following with the IRS:

  • A single transmittal form (Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return) for all of the returns filed for a given calendar year; and
  • A separate employee statement (Form 1095-C, Employer-Provided Health Insurance Offer and Coverage) for each full-time employee.

Substitute statements that comply with applicable requirements may be used, as long as the required information is included. ALEs using substitute forms instead of the official IRS versions may develop substitute forms themselves or buy them from a private printer. Publication 5223, General Rules & Specifications for Substitute ACA Forms 1094-B, 1095-B, 1094-C, and 1095-C and Certain Other Information, explains the requirements for the format and content of substitute statements to recipients. Only forms that conform to the official form and the specifications in Publication 5223 are acceptable for filing with the IRS. ALEs may not request special consideration.

DEADLINES FOR FILING WITH THE IRS AND FURNISHING STATEMENTS TO EMPLOYEES

The required forms generally must be filed with the IRS annually, no later than Feb. 28 (March 31, if filed electronically) of the year following the calendar year to which the return relates. Due to a delay, for the 2015 calendar year, returns were required to be filed no later than May 31, 2016, or June 30, 2016, if filed electronically. For the 2016 calendar year, returns were required to be filed no later than Feb. 28, 2017, or March 31, 2017, if filed electronically. For the 2017 calendar year, returns must have been filed by Feb. 28, 2018, or April 2, 2018 (March 31, 2018, being a Saturday), if filed electronically.

For the 2018 calendar year, returns must be filed by Feb. 28, 2019, or April 1, 2019 (March 31, 2019, being a Sunday), if filed electronically.

Each ALE must also furnish statements annually to its full-time employees, generally on or before Jan. 31 of the year immediately following the calendar year to which the statements relate. Due to a delay, for the 2015 calendar year, individual statements must have been furnished no later than March 31, 2016. For the 2016 calendar year, IRS Notice 2016-70 extended the due date for furnishing 2016 Forms 1095-B and 1095-C to individuals from Jan. 31, 2017, until March 2, 2017. For the 2017 calendar year, IRS Notice 2018-06 extended the due date for furnishing the 2017 Forms 1095-B and 1095-C to individuals from Jan. 31, 2018, until March 2, 2018.

For the 2018 calendar year, individual statements were required to be furnished by Jan. 31, 2019. However, on Nov. 29, 2019, IRS Notice 2018-94 extended the furnishing deadline for the 2018 calendar year to March 4, 2019. The extended deadline is March 4, rather than March 2 as in prior years, because March 2, 2019, is a Saturday.

Extensions may be available in certain circumstances. However, an alternate deadline is generally not allowed for ALEs with non-calendar year plans. Although ALEs may collect information on a plan year basis, employees will need to receive their individual statements early in the year in order to have the requisite information to correctly and completely file their income tax returns for that year.

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