As a reminder, employers subject to the new Affordable Care Act (ACA) information reporting requirements must furnish the first statements for the 2015 calendar year to employees on or before March 31, 2016.

Information Reporting Requirements

The ACA requires applicable large employers (ALEs)–generally those with 50 or more full-time employees, including full-time equivalents-to report information to the IRS and to their employees about their compliance with the “pay or play” provisions and the health care coverage they have offered, using Forms 1094-C and 1095-C.

Self-insuring employers that are not considered ALEs, and other parties that provide minimum essential health coverage, also must report information on this coverage to the IRS and to covered individuals, using Forms 1094-B and 1095-B.

Compliance Deadlines

The deadlines for calendar year 2015 are as follows:

• ALEs must furnish employee statements (Form 1095-C) to employees no later than March 31, 2016. The first IRS information returns (Forms 1094-C and 1095-C) must be filed no later than May 31, 2016 (or June 30, 2016 if filing electronically).
  • ALEs with fully insured plans must furnish the Form 1095-C to each employee who was a full-time employee for any month of the calendar year (and who was not in a limited non-penalty period).
  • ALEs with self-insured plans must furnish the Form 1095-C to any employee who enrolls in the health coverage, whether or not the employee was a full-time employee for any month of the calendar year.
• Small self-insuring employers that are not considered ALEs must furnish statements (Form 1095-B) to covered individuals no later than March 31, 2016. The first IRS information returns (Forms 1094-B and 1095-B) must be filed no later than May 31, 2016 (or June 30, 2016 if filing electronically).

Be sure to review our Information Reporting section within the Client Resource Center HR Library for additional information, guidance, and Q&As.