IRS Releases Final 2018 ACA Reporting Forms and Instructions

October 9, 2018

In late Sept. 2018, the Internal Revenue Service (IRS) released final 2018 forms and instructions for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.

Applicable large employers (ALEs), entities that employed 50 or more full-time and full-time-equivalent employees in the prior year, are required to report information about the health coverage they offer or do not offer to certain employees. To meet this reporting requirement, applicable large employers (ALEs) will use the following:

Employers that self-fund a minimum essential coverage plan are required to report coverage information about enrollees. To meet this reporting requirement, employers will use the following:

Information is reported on a calendar-year basis regardless of the employer’s health plan year or fiscal year.

2018 Forms and Instructions

The 2018 forms and instructions generally are the same as the prior year’s materials. The reporting requirements have been in place for several years now, so employers and their advisors should have little trouble working with the new materials for 2018.

Note that the new forms do include a format change for entering the names of persons enrolled in a minimum essential health coverage plan. In most cases, coverage is provided through a group insurance policy so the insurance carrier (not the employer) reports this information. If the coverage is self-funded, however, the employer is responsible for reporting the covered individuals’ names, either on Form 1095-C, Part III or Form 1095-B, Part IV. Previously, there was a single space for entering the full name, but now there are separate spaces for first name, middle initial and last name.

Due Dates

Employers must furnish 2018 forms to individuals is January 31, 2019, while the due date to file copies with the IRS, including the appropriate transmittal form, will depend on whether the employer files electronically or by paper. Entities that provide 250 or more forms to individuals are required to file electronically with the IRS.

The due dates for 2018 reporting are:

  • January 31, 2019: Deadline to furnish 2018 Form 1095-C (or 1095-B, if applicable) to employees and individuals.
  • February 28, 2019: Deadline for paper filing of all 2018 Forms 1095-C and 1095-B, along with transmittal form 1094-C or 1094-B, with the IRS.
  • April 1, 2019: Deadline for electronic filing of all 2018 Forms 1095-C and 1095-B, along with transmittal form 1094-C or 1094-B, with the IRS. (April 1 is the first business day following the usual due date of March 31.)

For specific questions regarding the forms, contact your local Marsh & McLennan Agency representative.