The Affordable Care Act (ACA) requires two types of reporting:

1. Section 6055 Minimum Essential Coverage Reporting: Insurers providing fully insured plans and employers providing self-insured plans must report the months members are covered by a health plan.

2. Section 6056 Employer Mandate Reporting: Applicable large employers must report information to demonstrate their compliance (or non-compliance) with the Employer Mandate.

Critical submission dates for the 2019 reporting year are rapidly approaching:

Some additional tips, reminders and new information for the 2019 reporting year have been provided below:

• Small employers with self-funded plans must complete Form 1095-B for every employee (and their dependents) covered on the health plan for one day or more in 2019. One Form 1094-B must also be submitted. Small employers with level-funded plans should check with their insurance carrier if they will be submitting these forms on their behalf. Insurance carriers may optionally provide this service for level-funded plans.
   
• Employers subject to the Employer Mandate must complete Form 1095-C for anyone who was a full-time employee for one day or more in 2019. Section III of Form 1095-C only needs to be completed if the employer provided a self-insured plan. Employers with self-insured plans must also complete Form 1095-C for any non-full-time employees who were enrolled in their health plan (e.g. part-time employees). One Form 1094-C must also be submitted by any employer who was subject to the Employer Mandate in 2019.
   
• This year, small employers with self-insured plans do not need to furnish Form 1095-B to employees provided they follow certain steps listed in IRS Notice 2019-63, which includes a website posting to employees that the forms will be available upon request. Similarly, employers subject to the Employer Mandate do not need furnish Form 1095-C to any non-full-time employees provided certain steps are taken.
   
• Good-faith reporting relief has been extended yet again for the 2019 reporting year. This generally means employers will not be penalized for incomplete or inaccurate reporting provided they timely report information to the IRS in good-faith. Penalties may still apply for non-compliance with the Employer Mandate.

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