Wednesday, February 22, 2017

Employer Deadlines Are Almost Here for Filing Mandatory IRS Forms

Dave Kyllo

The Internal Revenue Service has set the deadlines for mandatory forms required by the Affordable Care Act (ACA) that must be completed by an applicable large employer – employers with 50 or more full-time employees, including full-time equivalents. For calendar year 2016, Forms 1094-C and 1095-C are required to be filed with the IRS by February 28, 2017 or March 31, 2017 (if filing electronically.) 

 An applicable large employer also must furnish the Form 1095-C to each full-time employee on or before March 2, 2017. This due date reflects a 30-day extension from the general due date (that is, January 31 of the year immediately following the calendar year to which the information relates). This extension was provided by the IRS in Notice 2016-70 on November 18, 2016.   

These reporting requirements apply regardless of whether health coverage was offered to employees. The two IRS forms that are used for ACA reporting are:

Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return: used to report to the IRS summary information for each employer and to transmit Forms 1095-C to the IRS.
Form 1095-C, Employer-Provided Health Insurance Offer and Coverage: used to report required information to your employees and to report information about each employee to the IRS.

The IRS has a Frequently Asked Questions document about these two mandatory forms. For more information about these reporting requirements, go to Reporting of Offers of Health Insurance Coverage by Employers on

While there is much discussion in Washington about repealing and replacing the ACA, employers should continue to comply with the ACA requirements. This means that employers with 50 or more FTEs should plan on submitting the mandatory employer reporting forms to the IRS for the 2016 tax year.

 In addition, if an employer is currently renewing their employee health benefit plan, they should choose a plan that is ACA compliant. AHCA/NCAL Insurance Solutions was created to help members save money on their employee benefit plans. To explore your health plan options available through AHCA/NCAL Insurance Solutions, contact Dave Kyllo at 202-898-6312 or Nick Cianci at (202-898-2841) or email us at

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