ACA Reporting Requirements For Large Employers Begin In 2016

As the calendar turns the page to 2016, the Affordable Care Act’s (“ACA”) new reporting requirements officially launch. One of those new reporting requirements mandates that all Applicable Large Employers (“ALE”) must report information regarding their employees’ health care coverage by submitting specific forms to the IRS. Furthermore, ALEs must report this information to all full-time employees.

To determine whether your company qualifies as an ALE for a specific calendar year, look at the average size of your workforce during the prior year. If your company had an average workforce of at least 50 full-time employees, including full-time equivalent employees, then your company qualifies as an ALE.

All companies that qualify as an ALE for the 2015 calendar year must report health care coverage information to the IRS using 2 separate forms: 1095-C and 1094-C, both of which are available at ( These forms must be filed with the IRS no later than May 31, 2016, or June 30, 2016 if filed electronically.

In addition to reporting health care coverage information to the IRS, ALEs must also report coverage information to their employees. To do this, employers simply provide a statement to employees that includes the same information that the employer provided to the IRS. These statements must be given to employees by February 1, 2016.

Finally, for smaller employers who do not qualify as ALEs, there may still be filing requirements. If a non-ALE is a member of a controlled or affiliated service group that collectively has at least 50 Full-time Employees (including full-time equivalent employees), they are required to file Forms 1095-C and 1094-C with the IRS and provide that information to their employees. Companies could be in a controlled or affiliated service group if they have common owners, provide services for each other, or work together to provide services for other third parties. Further, smaller employers with self-funded health plans are also subject to IRS filing requirements.