Affordable Care Act Compliance: Form Clarification

November 2018 | Article

There are many forms individuals and businesses need to consider as they work to comply with the Affordable Care Act. Receiving and completing the appropriate form at the right time is key. The following discusses each of these forms in detail and can help you identify what you need to do to remain in compliance.

1095-A
Individuals who have an Exchange plan will receive form 1095-A from the Exchange. This form is used to report the premiums that they paid as well as note any advanced premium tax credit, or APTC, that they may have received. Individuals need to obtain this form prior to getting their 1040 prepared.

1095-B
Individuals who have fully insured plans will receive form 1095-B from the insurance company. This form exists to notify individuals of the months in which they had health insurance coverage.

1094-B and 1095-B
Small employers with self-insured plans need to file these forms with the IRS. The 1094-B is the transmittal form. The 1095-B, as mentioned above, reports the months in which the individual had health insurance. A copy needs to go to the individual that has coverage as well as to the IRS along with the transmittal for 1094-B.

Note: one day of coverage within a month is sufficient to indicate that the individual had coverage for that month.

1094-C and 1095-C
Large employers need to file both of these forms with the IRS. Employers must also provide a copy of the 1095-C to their employees. There is a misconception that insurance companies file this form on a business’s behalf, but in reality, all large employers are required to file these forms. The insurance companies are required to file form 1094/1095-B, not form 1094/1095-C.

If the large employer has a fully insured plan, they will need to fill out parts one and two of the 1095-C, as the insurance company will give employees/recipients a 1095-B to report the months in which the individuals had coverage. If the large employer had a self–funded plan, they will also need to fill out part 3 of the 1095-C, as the employee will not receive a 1095-B from the insurance company

Note: fully insured large employers do not provide forms to part-time or non-employees such as retirees.

Contact your Eide Bailly professional or a member of our ACA team with questions or for assistance completing or reviewing your ACA compliance forms.

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