ACA Reporting & Filing
Get the filings right the first time.
Accurate forms, defensible codes, and deadlines that hold — before the IRS asks.
Last reviewed: · Applies to: General ACA reporting mechanics; not specific to a single reporting year
Primary source: IRS ACA information reporting guidance. Dates, rates, thresholds, and penalty amounts change. Confirm the current figures against the primary source before acting.
Portions of this page are awaiting compliance review and are not represented as verified.
Forms reference
Who files what, and when.
| Form | Purpose | Who files | Furnish by | File by |
|---|---|---|---|---|
| 1095-B | Reports minimum essential coverage provided to employees and their dependents. | Self-funded employers that are not Applicable Large Employers, health insurance issuers, and government-sponsored programs. | Early in the following year | Late winter (paper) / spring (electronic) |
| 1095-C | Reports offers of coverage per employee; self-insured ALEs also report enrollment in Part III. | Applicable Large Employers, including self-insured ALEs. ALE status is determined by the full-time-equivalent count set in the statute and current IRS guidance. | Early in the following year | Late winter (paper) / spring (electronic) |
| 1094-C | Transmittal that accompanies 1095-C returns and reports monthly full-time counts and relief. | Applicable Large Employers filing 1095-C returns; one authoritative transmittal per EIN. | Not furnished to employees | Late winter (paper) / spring (electronic) |
1095-B
Reports minimum essential coverage provided to employees and their dependents.
- Who files
- Self-funded employers that are not Applicable Large Employers, health insurance issuers, and government-sponsored programs.
- Furnish by
- Early in the following year
- File by
- Late winter (paper) / spring (electronic)
1095-C
Reports offers of coverage per employee; self-insured ALEs also report enrollment in Part III.
- Who files
- Applicable Large Employers, including self-insured ALEs. ALE status is determined by the full-time-equivalent count set in the statute and current IRS guidance.
- Furnish by
- Early in the following year
- File by
- Late winter (paper) / spring (electronic)
1094-C
Transmittal that accompanies 1095-C returns and reports monthly full-time counts and relief.
- Who files
- Applicable Large Employers filing 1095-C returns; one authoritative transmittal per EIN.
- Furnish by
- Not furnished to employees
- File by
- Late winter (paper) / spring (electronic)
- Filing deadline
- Paper filing falls earlier than electronic; confirm both dates each year
- Furnishing to individuals
- Early in the year following the reporting year, per current IRS guidance
- Penalties per return
- Set per return and adjusted for inflation; see current IRS guidance
- Annual penalty cap
- A per-entity cap applies and is also inflation-adjusted
Filed wrong in a prior year? We handle corrections.
Corrected returns, replacement transmittals, TIN validation errors, and responses to IRS Letter 226-J or Letter 5699. Voluntary correction with a documented good-faith effort generally puts a sponsor in a better position than waiting for a notice.
PCORI fee
A small fee with a firm annual deadline.
Self-funded plan sponsors generally calculate and pay the PCORI fee themselves, since there is no carrier to do it. The calculation depends on the counting method chosen, which is applied consistently across the plan year. PCORI rates are adjusted periodically; the applicable rate depends on the plan-year ending date and current IRS guidance.
- Average covered lives calculated under the actual count, snapshot, or Form 5500 method
- Applicable per-life rate for your plan-year ending date, confirmed against current IRS guidance
- Reporting and payment with the second-quarter Form 720; confirm the current-year due date
- HRAs and multiple self-funded arrangements reviewed for double-counting
Common questions
Filing mechanics, answered.
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