Q: I understand that the final ACA Reporting forms have been released. Am I required to file and if so, what forms do I need to complete?

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A: Section 6056 reporting is required for all applicable “large” employers (ALE), which the ACA defines as having 50 or more full-time equivalent employees during the prior calendar year. This also includes employers who are part of a controlled group.

Section 6055 reporting is required for all employers who offer a self-insured health plan, level funded or an Individual Coverage Health Reimbursement Account (ICHRA) regardless of the employer size. If you have an HRA with a fully insured plan, you do not need to do the reporting for Section 6055.  Section 6055 reporting is still required, despite the fact that the individual mandate penalty has been reduced to $0.

All ALE’s are required to file forms 1094-C and 1095-C.   These forms fulfill the employers 6056 reporting as well as the 6055 reporting requirement. The largest change to the filing requirement is the plan start date is now required to be completed. In prior years, this field was optional. The 2020 Instructions for Forms 1094-C and 1095-C also clarify that only employers who offer an ICHRA must complete the employees age as of January 1, 2020.

Small employers who offer a self-insured plan, level-funded plan, or IHCRA Employers are required to file forms 1094-B and 1095-B.   As stated in the2020 Instructions for Forms 1094-B and 1095-B, an employer is not required to distribute the forms to the covered employees as long as the employer prominently posts a notice on its website stating that responsible individuals may receive a copy of their 2019 Form 1095-B upon request, accompanied by an email address and a physical address to which a request may be sent, as well as a telephone number that responsible individuals can use to contact the reporting entity. Employers are still required to furnish the forms to the Internal Revenue Service.

Individual forms must be supplied to employees by March 2, 2021 if you are an ALE or if you are a small employer who is distributing the forms to employees.  Forms are due to the I.R.S. by March 1, 2021 if filing by paper or March 31, 2021 if filing electronically

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