First ACA Information Returns Due in 2016

The Internal Revenue Service (IRS) released draft forms for 2015 to help employers prepare for the new information reporting provisions under the Affordable Care Act (ACA). Employers are required to report for the first time in early 2016 for calendar year 2015.


The ACA requires insurers, self-insuring employers, and other parties that provide minimum essential health coverage to report information on this coverage to the IRS and to covered individuals using Forms 1094-B and 1095-B. Large employers (generally those with 50 or more full-time employees, including full-time equivalents) are also required to report information to the IRS and to their employees about their compliance with the employer shared responsibility provisions (“pay or play”) and the health care coverage they have offered using Forms 1094-C and 1095-C.

Final versions of the 2014 forms were previously released for those employers that chose to voluntarily comply for the 2014 calendar year.

2015 Draft Forms

The following draft forms are now available for 2015:

As a reminder, Forms 1095-B and 1095-C must be electronically filed if the employer is required to file at least 250 of the specific form.

Changes to 2015 Draft Form 1095-C

Among other things, the last page of 2015 Draft Form 1095-C states that this Form is generally unchanged from the 2014 Form 1095-C, except for the addition of one new field titled “Plan Start Month.” This new field is optional for 2015, meaning that filers can choose to: (i) add this field and provide plan year information, (ii) add this field and enter “00,” or, (iii) leave this new field out (thus using the 2014 format). For 2016 and beyond, this field will be required.

In addition, 2015 Draft Form 1095-C includes a continuation sheet that filers use if they need to report coverage for more than six individuals.

For More Information

Additional details on the information reporting requirements for providers of minimum essential coverage, including self-insured employers, are available in IRS Questions and Answers.  More information about the information reporting requirements for large employers subject to “pay or play” is available in separate IRS Questions and Answers.

Please Note: The information and materials herein are provided for general information purposes only and are not intended to constitute legal or other advice or opinions on any specific matters and are not intended to replace the advice of a qualified attorney, plan provider or other professional advisor. This information has been taken from sources which we believe to be reliable, but there is no guarantee as to its accuracy. In accordance with IRS Circular 230, this communication is not intended or written to be used, and cannot be used as or considered a ‘covered opinion’ or other written tax advice and should not be relied upon for any purpose other than its intended purpose.

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