Affordable Care Act (ACA) Reporting Requirements – Frequently Asked Questions

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The Affordable Care Act, or ACA, requires employers to file forms to the IRS and to employees. Knowing how and when to comply with ACA reporting is both critical and complex. If not completed on time or correctly, your business is at risk of receiving a noncompliance citation and/or fine. To help your business make reporting easy, our compliance experts have gathered answers to the most commonly asked questions for ACA reporting requirements, guidance on which forms are required to complete, upcoming deadlines, and more to remain compliant.

New IRS Electronic Filing Threshold

As a reminder, the IRS changed electronic filing (E-Filing) requirements for ACA and other required tax reporting in 2024. The electronic-filing threshold for information returns decreased to 10 or more returns. The 10-or-more requirement applies in the aggregate to certain information returns that includes ACA Reporting Forms and other tax reporting forms, such as Form W-2s, Form 1099s, and Form 5330s. This means an employer may be required to file fewer than 10 ACA Reporting Forms but still have an electronic filing obligation based on other kinds of information returns filed.

General Question

How do I know whether to complete the B forms or C forms?

All applicable large employers (ALE) must file Forms 1094-C and 1095-C with the IRS and furnish a copy of the 1095-C to all full-time employees. The insurance carrier for a fully insured plan must complete Forms 1094-B and 1095-B. Generally, only employers that are non-ALEs with a self-insured plan will complete Forms 1094-B and 1095-B. For these two groups reporting on the B forms, the IRS stated that it will not assess a penalty for failure to distribute Form 1095-B to participants in cases where the reporting entity meets the following requirements:

1. Prominently place a notice on its website with an email address, physical address, and telephone number, where individuals can contact the entity to request a copy of the 1095-B; and
2. The reporting entity provides a copy of the 1095-B within 30 days of the request.

What is the deadline for filing and furnishing the forms?

• To IRS: February 28, 2025 (paper submission) or March 31, 2025 (electronic submission)
• To Employee: March 3, 2025

Are extensions available?

You can get an automatic 30-day extension of time to file with the IRS by completing Form 8809, Application for Extension of Time to File Information Returns. You must file Form 8809 on or before the due date of the returns.

There are no additional extensions for furnishing statements to employees.

What if I missed the deadline and didn't file for an extension? Are there penalties?

Make sure to complete, furnish, and file the forms as soon as possible. The IRS will reduce the penalties if late files and furnishings are completed within 30 days of the due date. Those failures will only be $60 per penalty per return for 2025. If corrected by August 1, 2025, the penalty increases to $130 per return. For any corrections made after August 1, 2025, the IRS can assess a penalty of $330 per return for failure to file a correct return. If employers fail to provide their employees with a correct return, an additional $310 penalty per return may be assessed. If the IRS determines that an employer intentionally disregarded the deadlines the penalty can increase to $630 per return.

FORM 1094-C: Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns

Form 1094-C: What is an “authoritative transmittal?”

If you have only one Form 1094-C, that Form 1094-C must report aggregate employer-level data for the ALE Member and be the Authoritative Transmittal. If multiple Forms 1094-C are being filed for an ALE Member so that all full-time employees’ Forms 1095-C are not attached to a single Form 1094-C transmittal, one of the Forms 1094-C must report aggregate employer-level data for the ALE Member and be the Authoritative Transmittal.

What is an Aggregate ALE Group member?

Companies that are part of a controlled group are an ALE member in the aggregate ALE group. Each ALE member must complete the Form 1094-C and 1095-C for their respective employees.

What should I check under “certifications of eligibility”?

You should consider the following two selections:

• Box A. Qualifying Offer Method – the ALE Member can certify that it made a Qualifying Offer (affordable based on Federal Poverty Level and minimum value) to one or more of its full-time employees for all months during the year in which the employee was a full-time employee.
• Box D. 98% Offer Method – the employer can certify that the ALE Member offered affordable health coverage providing minimum value to at least 98% of its employees for whom it is filing a Form 1095-C and offered minimum essential coverage to those employees’ dependents. Remember to factor in all months during which the individuals were employees of the ALE Member and were not in a Limited Non-Assessment Period.

How do I complete Part III(a)?

Check “yes” for the applicable month or all 12 months if you offered minimum essential coverage to at least 95% of your full-time employees.

What is the difference between Part III(b) and Part III(c)?

• Part III (b): Enter full-time employee count
• Part III (c): Enter total employee count (includes part-time employees and all others)

What should I enter in Part IV?

Each aggregate ALE member must cross-reference the name and EIN of all other entities in the controlled group.

FORM 1095-C: Employer-Provided Health Insurance Offer and Coverage

Form 1095-C: Which code should I enter on Line 14?

• 1A Qualifying Offer, Minimum essential coverage offered: Minimum Value to FT Employee Affordable Based on FPL To Spouse and Dependent
• 1B Minimum essential coverage offered: Minimum Value to Employee Affordable or Unaffordable To Employee Only
• 1C Minimum essential coverage offered: Minimum Value to Employee Affordable or Unaffordable To Dependent (not Spouse)
• 1D Minimum essential coverage offered: Minimum Value to Employee Affordable or Unaffordable To Spouse (not Dependent)
• 1E Minimum essential coverage offered: Minimum Value to Employee Affordable or Unaffordable To Spouse and Dependent
• 1F Minimum essential coverage offered: NOT Minimum Value Affordable or Unaffordable To Employee, Spouse, and/or Dependent
• 1G Self-insured coverage offered: To Non-Employee or Former Employee for Entire Calendar Year
• 1H No offer of coverage: For the entire month; or For part of the month
• 1J Minimum essential coverage offered: Minimum Value to Employee Affordable or Unaffordable To Spouse Conditionally
• 1K Minimum essential coverage offered: Minimum Value to Employee Affordable or Unaffordable To Spouse Conditionally To Dependent
• 1L Individual coverage HRA offered: To Employee Affordable Based on Primary Residence Zip Code
• 1M Individual coverage HRA offered: To Employee and Dependent Affordable Based on Primary Residence Zip Code
• 1N Individual coverage HRA offered: To Employee, Spouse and Dependent Affordable Based on Primary Residence Zip Code
• 1O Individual coverage HRA offered: To Employee Affordable Based on Primary Employment Site Zip Code
• 1P Individual coverage HRA offered: To Employee and Dependent Affordable Based on Primary Employment Site Zip Code
• 1Q Individual coverage HRA offered: To Employee, Spouse and Dependent Affordable Based on Primary Employment Site Zip Code
• 1R Individual coverage HRA Offered: Unaffordable to employee, employee and spouse, employee and dependent, or employee, spouse and dependent
• 1S Individual coverage HRA offered: To Non-Full-time Employee
• 1T Individual coverage HRA offered: To Employee and spouse (not dependents) with affordability determined by using employee’s primary residence location ZIP code
• 1U Individual coverage HRA offered: To Employee and spouse (not dependents) with affordability determined by using employee’s primary employment site ZIP code affordability safe harbor

What is the difference between code 1A and code 1E?

An offer of coverage under code 1A must be affordable based on the Federal Poverty Level safe harbor. Code 1E may be used for coverage that is affordable under any of the affordability safe harbors, or unaffordable.

What code should I enter on Line 16?

• 2A Employee not employed any day of the month
• 2B Employee not a full-time employee or was full-time only part of the month
• 2C Employee enrolled in coverage every day of the month
• 2D Employee in a waiting period, measurement period, or first month of employment with no waiting period
• 2E Employee offered union coverage on behalf of employer
• 2F Employee waived and coverage affordable based on W-2 safe harbor
• 2G Employee waived and coverage affordable based on federal poverty line safe harbor
• 2H Employee waived and coverage affordable based on rate of pay safe harbor

*When more than one code applies codes 2A – 2D supersede codes 2E – 2H. If code 2C applies, it supersedes all other codes.

Can I use the “All 12 months” Box for the cost of coverage on Line 15?

Only use this Box if the cost was the exact same for all 12 months. If the cost changes during the plan year, enter the applicable cost for each month. Non-calendar plan years typically cannot use the “All 12 months” box.

How do I report coverage that terminates on a date when the employee’s employment ends mid-month?

The employer cannot enter 2C on Line 16 because the employee was not enrolled in coverage for every day of the month. Alternatively, the employer should enter 2B to indicate that the employee was not a full-time employee for the entire month.

How do I report an employee in an initial measurement period for the entire year?

Employers should only complete the forms for its full-time employees. Until the employee completes the measurement period, no status is assigned so no reporting is required.

Should I complete the forms for non-employees?

The employer shared responsibility provision does not apply to non-employees, such as independent contractors, owners and other non-employees. There is no reporting requirement for non-employees under section 6056. However, under section 6055, self-insured plans must report on any covered non-employees.

How do I report an offer of COBRA or retiree coverage?

• Terminated During Reporting Year: Report as no offer of coverage – code 1H
• Reduction in Hours During Reporting Year: Report as an offer of coverage – typically code 1B, 1C, 1D, or 1E
• On Self-Insured COBRA All of Reporting Year: Report as an offer of coverage – code 1G

Do I need to complete Part III of the 1095-C?

Self-Insured Plan: Yes; Fully Insured Plan: No.

How do I complete 1095-C Part III(e)?

Check all months that the employee, employee’s spouse, or employee’s dependent was covered for at least one day of the month.

How do I report a spouse or dependent covered on my self-insured plan when the employee is not receiving a 1095-C?

To report coverage for a spouse or dependent only, complete Forms 1094-B and 1095-B and check all months that the individual was covered for at least one day of the month.

IRS Filing

Am I required to file electronically?

You will have to file your ACA Reporting Forms electronically if you have to file 10 or more tax informational returns. When counting how many tax information returns you must file, you must count all ACA Reporting Forms and other tax information returns you may need to file, such as W-2s, 1099s, 5330s, and 5500s. For more information on if you must E-File and how you would E-File, visit this IRS websites on Filing Information Returns Electronically (FIRE) and Affordable Care Act Information Returns (AIR) System. Failing to file electronically when required to do so may result in a penalty of $310 per return unless a waiver is approved or establishing reasonable cause.

Did the IRS create more detailed instructions for how to complete the forms?

Yes, annually the IRS issues updated forms and Instructions for Forms 1094-C and 1095-C and Instructions for Forms 1094-B and 1095-B.

Navigating ACA requirements can feel complex, but you don’t have to tackle it alone. Reach out to OneDigital's team of HR Consulants to streamline the reporting process and ensure your organization is compliant.