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ACA Reporting – Final Forms for 2018 Released

October 17, 2018

The Internal Revenue Service (IRS) has released the final forms for 2018 ACA Reporting under IRS code Sections 6055 and 6056.  Applicable large employers (ALEs) will use 1094-C and 1095-C to report under Section 6056 as will ALEs who sponsor self-insured plans for combined 6055 and 6056 reporting.  For entities that are reporting only under Section 6055, including self-insuranced plan sponsors that are not ALEs, there are forms 1094-B and 1095-B.

Although the 2018 forms and instructions are considerably similar to the 2017 forms, the form 1095-C states that the “Plan Start Month” box in Part II will remain optional for 2018.  It was previously indicated by the IRS that this box may become mandatory to the 2018 Form 1095-C.

Important Dates to Remember

  • Furnish individual satements for 2018 by January 31, 2019
  • IRS returns for 2018 must be filed by Feburary 28, 2019.
  • IRS returns for electronic filers (again for 2018) by April 1, 2019 (March 31, 2019 is on a Sunday)

It is important that employers familiarize themselves with these forms and instructions as they prepare to use them for 2018 calendar year reporting.

ACA Reporting History

Reporting rules were created under the Affordable Care Act (ACA), Code Sections 6055 and 6056 that require certain employers to provide information to the IRS about the health plan coverage they they offer (or do not offer) or provide to their employees.  Annually, each reporting entity must file the following with the IRS:

  • A separate statement (Form 1095-B or Form 1095-C) for each individual who is provided with minimum essential coverage (for providers reporting under Section 6055), or for each full-time employee (for ALEs reporting under Section 6056)
  • A transmittal form (Form 1094-B or Form 1094-C) for all of the returns filed for a given calendar year.

In general, forms must be filed with the IRS no later than February 28th (March 31st, if filed electronically) of the year following the calendar year to which the return relates. Individual statements must be furnished to individuals on or before January 31st of the year immediately following the calendar year to which the statements relate.

According to the IRS, information returns under Sections 6055 and 6056 may continue to be filed after the filing deadline (both on paper and electronically). Employers that miss filing deadlines should continue to make efforts to file their returns as soon as possible.

For more information Employee Benefits for your organization, or to speak with one of our advisors, email Jason Della Penna, Senior Vice President at Brown & Brown Benefit Advisors at

Brown & Brown Benefit Advisors