The IRS has released the final Forms 1094-B, 1095-B, 1094-C, and 1095-C for calendar year 2018 reporting with minimal changes. Employers are required to report in early 2019 for calendar year 2018.
The following forms are now available for calendar year 2018 reporting:
Form 1094-B (transmittal)
Form 1094-C (transmittal)
Health insurance issuers and carriers are encouraged (but not required) to report coverage in catastrophic health plans enrolled in through the Marketplace for months in 2018.
Who Must File
An ALE Member (generally those with 50 or more full-time employees, including full-time equivalents or FTEs) must file one or more Forms 1094-C (including a Form 1094-C designated as the Authoritative Transmittal, whether or not filing multiple Forms 1094-C), and must file a Form 1095-C for each employee who was a full-time employee of the ALE Member for any month of the calendar year. Generally, the ALE Member is required to furnish a copy of the Form 1095-C (or a substitute form) to the employee.
Section 6055 (1094B/1095B)
- Provide report to individuals and IRS regarding minimum essential coverage.
- This is for the purposes of the individual mandate.
- Insurance providers, government agencies, multiemployer plans, employers (of any size) that sponsor self-insured plans.
- This will include Retiree Health Reimbursement Arrangements (HRAs).
- This will NOT include HRAs that are integrated with employer sponsored major medical plans.
- Employer and employee identifying data (i.e. name, address, TIN for individuals covered) for each month during which an individual is covered.
Section 6056 (1094C/1095C)
- Provide report to IRS and individuals regarding offer of coverage.
- This is for purposes of administering the employer mandate and premium tax credit.
- Large employers subject to the Affordable Care Act (ACA). Large employer in this context will be employers that are considered Applicable Large Employers (ALE).
- Employer identifying information.
- Plan data including employee cost, time offered, etc. on a month by month basis.
- Identifying information for all full-time employees.
ALE Members that offer health coverage through an employer-sponsored self-insured health plan must complete Form 1095-C, Parts I, II, and III, for any employee who enrolls in the health coverage, whether or not the employee is a full-time employee for any month of the calendar year.
An employer that offers employer-sponsored self-insured health coverage but is not an ALE Member should not file Forms 1094-C and 1095-C, but should instead file Forms 1094-B and 1095-B to report information for employees who enrolled in the employer-sponsored self-insured health coverage.
When To File
Employers will meet the requirement to file if the forms are properly addressed and mailed on or before the due date. If the due date falls on a weekend or legal holiday, then the due date is the following business day. A business day is any day that is not a Saturday, Sunday, or legal holiday.
Filers of Form 1095-B must furnish a copy by January 31, 2019, to the person identified as the “responsible individual” on the form for coverage in 2018.
For forms filed in 2019 reporting coverage provided in calendar year 2018, Forms 1094-B and 1095-B are required to be filed by February 28, 2019, or April 1, 2019, if filing electronically.
An ALE Member must furnish a Form 1095-C to each of its full-time employees by January 31 of the year following the year to which the Form 1095-C relates. Forms 1095-C for the 2018 calendar year must be furnished by January 31, 2019.
Generally, employers must file Forms 1094-C and 1095-C by February 28 if filing on paper (or March 31 if filing electronically) of the year following the calendar year to which the return relates. For calendar year 2018, Forms 1094-C and 1095-C are required to be filed by February 28, 2019, or April 1, 2019, if filing electronically.