ACA Reporting Requirements Explained

Each year, certain employers and health coverage providers must report information about employer-sponsored health coverage to the IRS. This process, known as Affordable Care Act reporting, generally involves preparing Forms 1094 and 1095, submitting them to the IRS, and providing required coverage statements to employees or other covered individuals.

These forms document who was offered health coverage, who enrolled, and when that coverage was available during the calendar year. The IRS uses this information to administer the ACA’s employer mandate, verify enrollment in minimum essential coverage, and help determine eligibility for premium tax credits.

Key Takeaways

• Level-funded and self-insured plans must report, even under 50 employees.
• The IRS treats level-funded plans as self-insured for ACA reporting.
• Large employers file 1094-C/1095-C; smaller self-insured plans file 1094-B/1095-B.

Many employers assume ACA reporting applies only to Applicable Large Employers, generally businesses that employed an average of at least 50 full-time and full-time equivalent employees during the preceding calendar year. IRS regulations implementing the ACA employer mandate defines “full-time” as averaging at least 30 hours of service per week or 130 hours of service per month. The IRS provides two methods for determining employees’ full-time status: the monthly measurement method and the look-back measurement method.

That distinction is especially important for small employers sponsoring level-funded plans: even if an employer is not subject to the ACA employer mandate, it may still have a federal reporting obligation because a level-funded plan is generally treated as a self-insured plan.

Why Does ACA Reporting Matter?

ACA information reporting helps the IRS determine:

• Whether an Applicable Large Employer offered qualifying health coverage (to its full-time employees)
• Whether individuals were enrolled in minimum essential coverage at minimum value
• Whether the offer of coverage was affordable for employee-only coverage
• Whether an employer may owe an employer shared responsibility payment

Two sections of the Internal Revenue Code drive most employer ACA reporting obligations:

• Section 6055 requires providers of minimum essential coverage to report information about the individuals enrolled in that coverage.
• Section 6056 requires Applicable Large Employers to report information about the health coverage offered to full-time employees.

Section 6056 is tied to employer size. Section 6055 is tied to the provision of coverage, including coverage through a self-insured or level-funded plan.

That is why an employer with fewer than 50 full-time and full-time equivalent employees may still be subject to ACA reporting requirements.

Do Small Employers Have to Complete ACA Reporting?

A small employer is generally not subject to the ACA employer mandate if it employed fewer than 50 full-time and full-time equivalent employees during the preceding calendar year.

However, that does not automatically exempt the employer from every aspect of healthcare market reform or ACA reporting requirements.

A non-ALE that sponsors a fully insured plan does not file Forms 1094 or 1095; the insurance carrier reports the individuals covered and their months of coverage. However, a non-ALE that sponsors a self-insured health plan, including a level-funded plan, is responsible for reporting that information to the IRS.

Why Do Level-Funded Employers Have ACA Reporting Responsibilities?

Level-funded plans combine predictable monthly payments with the possibility of receiving money back when claims are lower than expected. However, the underlying arrangement differs from a traditional fully insured health plan.

With a fully insured plan, the employer pays premiums to an insurance carrier, and the carrier assumes the claims risk. With a level-funded arrangement, the employer generally funds employee claims while stop-loss insurance helps limit exposure to unexpectedly high costs.

For ACA reporting purposes, the IRS treats level-funded plans as self-insured plans under IRC §§ 6055 and 6056.

That distinction has important compliance consequences. A small employer can be exempt from the employer mandate but still be responsible for reporting the employees and family members enrolled in its level-funded or self-insured plan under Section 6055.

Which ACA Forms Does an Employer Need to File?

The correct IRS forms depend on employer size and plan funding.

Non-Applicable Large Employer With a Fully Insured Plan

An employer that is not an Applicable Large Employer and sponsors only a fully insured plan generally has no ACA filing requirement.

The insurance carrier is generally responsible for reporting coverage under Section 6055.

Non-Applicable Large Employer With a Level-Funded or Self-Insured Plan

An employer that is not an Applicable Large Employer but sponsors a level-funded or self-insured health plan generally files:

• Form 1095-B for each individual enrolled in the plan
• Form 1094-B to transmit the Forms 1095-B to the IRS

This reporting must include employees, spouses, dependents, COBRA participants, and other individuals enrolled in the plan.

Applicable Large Employer With a Fully Insured Plan

An Applicable Large Employer generally files:

• Form 1095-C for each employee who was full-time for at least one month during the calendar year
• Form 1094-C to transmit the Forms 1095-C and provide employer-level to the IRS

The insurance carrier generally handles the separate Section 6055 reporting for individuals enrolled in the fully insured plan.

Applicable Large Employer With a Level-Funded or Self-Insured Plan

An Applicable Large Employer sponsoring a level-funded or self-insured plan generally uses Forms 1094-C and 1095-C to report both the offer of coverage and enrollment information.
Enrollment information for employees and their covered family members is generally reported in Part III of Form 1095-C. Certain nonemployee enrollees, such as some retirees or nonemployee COBRA participants, may be reported using Forms 1094-B and 1095-B instead.

How Can an Employer Determine Its ACA Reporting Requirements?

Begin by asking two questions:

1. Was the organization an Applicable Large Employer for the reporting year?
2. Was the health plan fully insured, level funded, or self-insured?

The answers provide a starting point for identifying the applicable forms.

Controlled-group and common ownership rules, plan funding changes, mergers, acquisitions, and other circumstances can affect an employer’s ALE status and responsibilities.

How Do Controlled-Group Rules Affect ACA Reporting?

An organization cannot always determine its Applicable Large Employer status by looking at one legal entity in isolation.

Businesses with common ownership may need to combine employees across related entities when determining whether they meet the threshold of 50 full-time and full-time equivalent employees. A company with fewer than 50 employees could therefore be part of an Aggregated Applicable Large Employer Group.

Once that status is established, each Applicable Large Employer member generally files under its own Employer Identification Number and reports information for its own employees.

Employers should review ownership relationships and organizational changes before determining which ACA reporting rules apply.

What Are the ACA Reporting Deadlines?

ACA reporting covers a calendar year, regardless of the employer’s health plan year.

The general federal deadlines are:

• Statements to individuals: Due March 2 following the reporting (March 1 for leap years)
• Paper filing with the IRS: Although only available to employers who file fewer than 10 aggregated forms (Forms 1095 + W-2, 1099, etc.) is due February 28
• Electronic filing with the IRS: Due March 31

Employers should confirm the exact dates published for each reporting year because the due date falls to the next business day when the date falls on a weekend or holiday.
An automatic 30-day extension of the IRS filing deadline may generally be requested by submitting Form 8809 on or before the original filing deadline.

When Should Employers Begin Preparing for ACA Reporting?

ACA reporting should not begin in February or March.

Employers may need information from payroll, HR, benefits administration, insurance carriers, third-party administrators, and COBRA vendors. Waiting until filing season can leave little time to resolve missing Social Security numbers, incorrect employee classifications, enrollment discrepancies, or conflicting records.

A stronger year-round process includes:

• Confirming annually whether the organization is an Applicable Large Employer
• Reviewing controlled-group and common ownership relationships
• Identifying whether each health plan is fully insured, level-funded, or self-insured
• Tracking full-time status and coverage offers monthly
• Reconciling employee and dependent enrollment information
• Verifying names, Social Security numbers, birth dates, and addresses
• Accounting for new hires, terminations, individuals on leaves of absence, COBRA participants, and dependents
• Reviewing affordability and offer-of-coverage data
• Correcting data before forms are generated and transmitted

For level-funded plans, the carrier often acts as the third-party administrator and may prepare or even submit ACA forms as part of its services. But because level-funded plans are considered self-insured for ACA reporting purposes, the legal responsibility for accurate, timely, and complete filing stays with the employer as plan sponsor. Employers should always verify the underlying data, confirm the filing was accepted by the IRS, and follow up on any errors before assuming the obligation is satisfied.

Do Level-Funded and Self-Insured Plans Have to Pay the PCORI Fee?

ACA information reporting is not the only compliance obligation associated with self-insured and level-funded plans.

The ACA created the Patient-Centered Outcomes Research Institute to study clinical effectiveness and health outcomes. To finance the institute’s work, a small annual fee, commonly called the PCORI fee, generally applies to all group health plans. Sponsors of level-funded and self-insured health plans are responsible for paying the PCORI fee and filing, regardless of plan size.

The fee is calculated using the applicable rate and the plan’s average number of covered lives. It is reported and paid annually using IRS Form 720, generally by July 31 of the calendar year following the end of the applicable plan year.

Because PCORI applies by plan year while ACA information reporting operates by calendar year, employers should manage the two requirements on separate compliance calendars.

Do State Healthcare Reporting Requirements Apply?

Federal filing is not always the end of the process. A handful of states and the District of Columbia have enacted their own individual health coverage mandates, separate from the ACA’s now zeroed out federal individual mandate, and require employers or coverage providers (including self-insured and level-funded plan sponsors) to file a parallel report confirming who had enrolled in coverage. Their deadlines, filing methods, and furnishing rules may differ from federal requirements.

Employers with employees or covered individuals in multiple states should determine whether additional state reporting applies. An IRS filing may not automatically satisfy every state obligation.

How Can Mitratech Mineral Help With ACA Reporting?

Knowing that you need to file is only the beginning. Employers still have to gather data across multiple systems, confirm the right forms, validate employee and dependent information, and resolve errors before and after filing.

The Mitratech Mineral ACA Reporting Hub brings ACA and applicable state reporting into one workflow: organizing and validating data, generating Forms 1094/1095-B and C, flagging potential errors before filing, and handling distribution, submission, and status monitoring afterward. For employers who want more hands-on support, ACA Expert-Driven Filing adds direct guidance from ACA reporting professionals, particularly useful for employers with limited internal HR resources, complex ownership structures, multiple data sources to reconcile, or past filing errors to resolve.

Watch On-Demand: ACA Compliance 101

Want to go deeper on the forms, responsibilities, and deadlines covered in this guide? I walk through practical, step-by-step guidance for preparing your data and approaching filing season with confidence in my on-demand webinar, ACA Compliance 101: Getting Your Filing Right.

Ready to put this into practice? Explore the Mitratech Mineral ACA Reporting Hub.

This content is provided for informational purposes and does not constitute legal or tax advice. Employers should consult qualified advisers regarding their specific reporting obligations.