Time to Prepare for 2016 ACA Reporting

Time to Prepare for 2016 ACA Reporting

The Internal Revenue Service (IRS) has released 2016 draft forms for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.

  1. Forms 1094-B and 1095-B will be used by entities reporting under Section 6055, including self-insured plan sponsors that are not applicable large employers (ALEs). Draft instructions were released on Aug. 10, 2016.  NOTE: An ALE is an employer who averaged 50 or more full-time employees including full-time equivalents during the preceding calendar year (e.g. calendar year 2015).  To read more about the ALE calculation, please click here
  1. Forms 1094-C and 1095-C will be used by ALEs to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans. Draft instructions for these forms were also released on Aug. 1, 2016.

Minor changes were made to the forms, including the addition of two new “Offer of Coverage” codes for use on Form 1095-C.  The draft instructions also included some clarifications.  To read more about the draft IRS Forms, click here.


Forms 1095-B/C must be issued to employees by January 31, 2017.  IRS Forms 1094-B/C must be filed with the IRS along with the 1095-B/Cs issued in January by February 28, 2017 if filing on paper, or March 31, 2017 if filing electronically.

While it is important to note that non-ALEs sponsoring fully-insured health plans are generally exempt from ACA reporting requirements, those employers subject to reporting requirements should begin planning their strategy for complying with the 2016 reporting deadlines.  During the 2015 reporting cycle, many employers engaged third-parties for reporting assistance (i.e. payroll vendors).  If your company is interested in obtaining recommendations for reporting services, or if you have questions about ACA reporting generally, please contact your Kistler Tiffany Benefits Consultant.