The Affordable Care Act (ACA) continues to raise compliance questions for many businesses. The most recent question surrounds IRS Forms 1094 and 1095.

Both of these forms are filed to record the employer provided health insurance coverage that is required under the ACA. The difference? Like many things ACA-related, it’s not so black and white. So, let’s dive in a little deeper.

FORM 1094

Section 6055 states Form 1094 must be provided to the IRS to report minimum essential health care coverage.

Purpose: This is a reporting form that provides information to the IRS about health insurance coverage the employer provides.
Form is provided to: The IRS by either the health insurance carrier or self-insured plan sponsor.
Deadline: The form is due the last day of February by mail, or the electronic filing is due the last day of March.
1094-B vs. 1094-C: If you provide health insurance coverage to your employees, no matter the size of your business, 1094-B will be completed for you. Form 1094-C is a requirement for Applicable Large Employers (ALE), or those with 50 or more full-time equivalent employees. In this case, if you are an ALE, you will receive both Forms 1094-B & 1094-C.
Who is responsible: Form 1094-B will be completed by the carrier or plan sponsor. Form 1094-C is completed by the employer or members of the applicable large employer (ALE).
 

FORM 1095

Section 6056 states Form 1095 must be provided to the IRS and employees about the health insurance coverage that was offered by the employer.

Purpose: This is the employee statement that is provided to help provide information around tax time about employee eligibility for tax credits.
Form is provided to: The IRS and covered employees.
Deadline: The employee statement is due to employees by the last day of January. The mailed version is due the last day of February and the electronic filing is due the last day of March.
1095-B vs. 1095-C: If you provide health insurance coverage to your employees, no matter the size of your business, 1095-B will be completed and provided to you. 1095-C is a requirement for Applicable Large Employers (ALE), or those with 50 or more full-time equivalent employees. In this case, if you are an ALE, you will receive both Forms 1095-B & 1095-C.
Who is responsible: Form 1095-B will be completed by the carrier or plan sponsor. Form 1095-C is completed by the employer or members of the applicable large employer (ALE).
 

More information available at IRS.gov. Click here for the IRS Reporting Flyer on both Forms 1094 and 1095.