Required ACA Reporting


The IRS recently announced that it has extended the 2020 deadline for insurers, self-insured employers, applicable large employers (ALE), and other coverage providers to provide Forms 1095-B and 1095-C to individuals who received health insurance coverage in 2019.

While the recent tax reform legislation did not repeal the Affordable Care Act (ACA) Individual Mandate, however it reduced the penalty for individuals who fail to purchase health insurance for months beginning after December 31, 2018 to $0. Form 1095-B is not required if the insurer posts on their website that the form is available upon request and provides the Form 1095-B within 30 days of a participant's request. Self-funded plans are still required to provide Form 1095-C by required dates.

Under the Individual Shared Responsibility provision of the Affordable Care Act (ACA), a tax penalty* is imposed on individuals that do not maintain coverage under a health plan that provides minimum essential coverage (MEC). The reporting requirements of MEC are declared in Internal Revenue Code (IRC) Section 6055.

*Tax reform legislation reduced the penalty on individuals to $0 for months beginning after December 31, 2018.


Under the Individual Shared Responsibility provision of the Affordable Care Act (ACA), a tax penalty* is imposed on individuals that do not maintain coverage under a health plan that provides minimum essential coverage (MEC). The reporting requirements of MEC are declared in Internal Revenue Code (IRC) Section 6055.

6055 Reporting on Form 1095-B

Provided by Insurer for insured medical plan; by employer for a self-insured medical plan

Provided to each covered “responsible individual” (e.g., employee, COBRA QB, retiree)

Provided by March 2, 2020 for coverage in prior calendar year

Transmitted with employer’s Form 1094-B to IRS by February 28, 2020 (March 31, 2020 if filed electronically)

Some HRAs are subject to being reported



The Play-or-Pay provision of the ACA can impose excise tax penalties on applicable large employers (ALEs) not offering their group medical plan to enough full time employees and dependents or the coverage offered is not of minimum value and affordable. The ALE’s reporting requirements are declared in IRC Section 6056.


The Play-or-Pay provision of the ACA can impose excise tax penalties on applicable large employers (ALEs) not offering their group medical plan to enough full time employees and dependents or the coverage offered is not of minimum value and affordable. The ALE’s reporting requirements are declared in IRC Section 6056.



6056 Reporting on Form 1095-C

Provided by applicable large employer (ALE)

Provided to each full time employee

Provided by March 2, 2020 for coverage offered in prior calendar year

Transmitted with employer’s Form 1094-C to IRS by February 28, 2020 (March 31, 2020 if filed electronically)

Some HRAs are subject to being reported


For downloads and more information on the Affordable Care Act, be sure to visit Keeping Up with Health Care Reform and Compliance Buzz.