2019 ALE 1095-C & 1094-C Form Reporting
Employers with at least 50 full-time equivalent employees (Applicable Large Employers or ALEs) have the following obligations under the ACA reporting requirements using Forms 1095-C and 1094-C:
- Prepare separate information returns for individuals
- Furnish the individuals with copies of the information returns
- Submit a single transmittal form to the IRS with consolidated information about the individual returns.
In addition, all self-insured employers also have reporting responsibility in their role as insurers (rather than employers) and may need to use Forms 1094-B and 1095-B depending upon the circumstances. Contact your Northwestern Benefit consultant for more information about self-funded plan reporting.
Which form should we use?
- Fully-insured ALEs should provide Form 1095-C to full-time employees and file Form 1094-C with the IRS.
- Self-insured ALEs should provide Form 1095-C (or 1095-B) to full-time employees and covered individuals, and file the corresponding Form 1094-C (or 1094-B) to the IRS.
- Small self-insured non-ALE employers should provide Form 1095-B to covered individuals and file the corresponding Form 1094-B to the IRS.
Important Due Date Delay:
On November 29, 2018, the IRS extended the due date for employers to furnish the following forms TO INDIVIDUALS from January 31, 2019, to March 4, 2019
- 2018 Form 1095-B, Health Coverage,
- 2018 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage
However, the IRS did NOT extend the due date for filing to the IRS the 2018 Forms 1094-B, 1095-B, 1094-C, or 1095-C. Those due dates are still
- February 28, 2019, if not filing electronically, and
- April 1, 2019, if filing electronically.
This guidance can be found in IRS Notice 2018-94, which will be formally published on December 17, 2018. For additional information, see the 2018 Instructions for Forms 1094/5.
Please contact your Benefits Consultant if you have specific questions.