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2015 Affordable Care Act Reporting Requirements

When to Report

Must be post marked by January 31st

Small (49 fulltime* or fewer employees):  Forms 1094-B (transmittal) and 1095-B

  • For fully insured employers, the insurance carrier will provide the required reporting information to each employee and the IRS on form 1094-B and 1095-B
  • Currently the employers with 49 for less employees will not have to file any extra tax forms for ACA requirements

Large (50 fulltime* or more employees): Form 1094-C (transmittal) and 1095-C
What needs to be reported to IRS:

  • Business name, date, EIN, and telephone number of contact
  • Certification as to whether the employer offers to its full time employees and dependents the opportunity to enroll in MEC (Minimum Essential Coverage) under an eligible employer sponsored plan by calendar month for all 12 months
  • The number of full-time employees and/or FTE’s for each calendar month during the calendar year, by calendar month for all 12 months
  • Type of healthcare coverage for each employee (ie: single, couple, employee and dependents or family)
  • For each full-time employee, the employee's share of the lowest cost monthly premium for self-only coverage providing minimum value offered to that full-time employee under an eligible employer-sponsored plan, by calendar month;
    • Example: company offers 3 levels of coverage with each level increasing in price and coverage.  Employee elects to choose level 3, the most expensive and highest coverage.  Employer is required only to report the cost of the level 1 premium.
  • If the plan changed during the year or renews on a date other than December 31, the employees’ data for each month needs to reflect the plan changes.
  • Name, address TIN (or date of birth if TIN is not available of primary insured)
  • Names, dates of coverage and TIN (or date of birth) and months of coverage for each individual covered under the policy or program

Form 1095C needs to be reported to the Employee, containing:

  • Name, address, SSN
  • Code indicating type of healthcare coverage for the year or by each specific month of the year if the coverage changed during the year.

Self-Funded Employers/Administrative Servicing Only Plans (ASO)

  • reporting is required of the employer regardless of size
    • small employers use 1094-B and 1095-B
    • large employers use 1094-C and 1095-C


  • Penalties are substantial, $100/ day up to $1.5M per calendar year

*In general, a full time employee is considered one who works 30 hours a week or 130 aggregate hours a month.
FYI--20 employees each working 15 hours per week will count as 10 full time equivalent employees.
Employee counts are based on 2014 employment records.


Links to information on the Affordable Care Act and Reporting

50 of more fulltime employees:
FORM 1094-C
FORM 1095-C

49 or fewer fulltime employees:
FORM 1094-B
FORM 1095-B

Employer Shared Responsibility Provisions
Frequently Asked Questions on Employer Shared Responsibilities
Transition Relief

Other Helpful Links and Websites:

WI Department of Revenue

WI Where’s my Refund?

Internal Revenue Service

IRS Where’s my refund?

Where’s my Amended Return?