Common Misconceptions About The New ACA Reporting Requirements – (Forms 1094C, 1095C and 1094B, 1095B)

With so much changing within our healthcare systems it can be easy for employers to become overwhelmed and flat out confused!  One of the major sources of headache and confusion pertains to the ACA reporting requirements which will take effect in 2016 for the reporting year 2015.  Listed below are some of the biggest misconceptions to be aware of.


  • Misconception #1: Penalty relief is available for ALL types of reporting errors.
  • The Truth: Penalty relief is provided for incomplete or incorrect information provided on the 2015 statements however the relief is only provided to those that can show good faith efforts to comply.  Those seeking penalty relief must also be able to show that their reporting information was submitted on time.
  • Misconception #2: All employers are required to file electronically.
  • The Truth: Only entities that have 250 or more returns are required to file electronically.  Entities with less than 250 returns can chooses to file electronically or on paper.
  • Misconception #3: Large employers that offer self-funded and fully-insured health plans will be required to use both sets of forms (1094C, 1095C and 1094B, 1095B).
  • The Truth: Employers that offer both types of health plans will only be required to complete Forms 1094C & 1095 C since 1095C includes separate sections for reporting each of the two plan types.
  • Misconception #4: Only large employers that sponsor group health plans are required to report.
  • The Truth: In addition to the large employers, employers of ANY SIZE that are self-insuring their employees must also report this information to the IRS on their covered employees.
  • Misconception #5: Employers that qualify for transition relief from the Employer Shared Responsibility or “Pay or Play” penalties do not have to report.
  • The Truth: Large employers (50-99 full-time employees) that are eligible for transition relief are still subject to the reporting requirements for 2015.  These employers must certify on their Form 1094C that they meet all of the eligibility criteria.

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