Final 2016 ACA Reporting Requirements

The Internal Revenue Service (IRS) has released final forms and instructions for the information reporting provisions under the Patient Protection and Affordable Care Act (the “PPACA”). Compliance is mandatory for affected employers. Failure to file the required informational returns or filing incomplete or inaccurate forms could result in reporting penalties and penalties under the ACA’s employer shared responsibility provisions. Employers should be prepared now to report for the first time in early 2016 for calendar year 2015. For more information on the final rules on this IRS information reporting for employers, please see the IRS ACA Reporting webpage.


The following final forms and instructions are now available for 2015 (minor changes were made to some of the forms and both sets of instructions):

  • Form 1094-C (transmittal)

  • Form 1095-C (employee statement)

  • 2015 Instructions for 1094-C and 1095-C

  • Form 1094-B (transmittal)

  • Form 1095-B (employee statement)

  • 2015 Instructions for 1094-B and 1095-B

Employers should be prepared now to comply with these reporting requirements. The information needed to complete these forms includes whether the employee and dependents were offered coverage, the employee-only cost of coverage, and identifying information not only for covered employees, but also for covered dependents (Social Security number, or date of birth if the dependents’ Social Security number could be obtained). Employers must also report the monthly count of the total number of employees, the total of full-time employees, and the reasons why the employer is not responsible for coverage in a given month. Controlled-group status of the employer and changes to employer and employee status during the year will create additional complexities. The information must be captured and reported for each month of the calendar year.


Employers are advised to consult with their tax, HRIS/payroll, and legal advisors for assistance with specific issues/complexities regarding form preparation, appropriate eligibility and hours tracking rules, and the actual implementation of the data gathering, tracking, and reporting rules. Should you have questions about this or any aspect of federal health insurance reform, contact your Conner Strong & Buckelew account representative toll free at 1-877-861-3220. For a complete list of Legislative Updates issued by Conner Strong & Buckelew, visit our online Resource Center.

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