IRS Reporting Requirements – Final Forms and Instructions

On 9/17/2015, the IRS issued final forms and instructions for employer reporting relating to insured health plan coverage. The forms will be used to enforce Affordable Care Act employer penalties and individual mandate and tax credit eligibility rules with mandatory reporting starting in 2016 for the tax year 2015. Large employers with 50 or more full-time employees (including full-time equivalents) are required to complete these forms.

Form 1094-C is the Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns. This form is used to report aggregate employer level data on each employee. Form 1094-C is used to provide summary information for each employer, and each employer will submit this form to the IRS.

Form 1095-C is the Employer-Provided Health Insurance Offer and Coverage. Form 1095-C will be submitted to the IRS and will be provided to each employee as it includes information about the health insurance offered to them.   This form must be filed for everyone who was a full-time employee of the employer for any month of the calendar year.

These final versions include:

  • Forms 1094-C and 1095-C (for Applicable Large Employer reporting and self-insured large group Minimum Essential Coverage reporting)
  • Forms 1094-B and 1095-B (for insurance carrier and small employer Minimum Essential Coverage reporting)
  • The corresponding instructions

These reports are due in January 2016 for coverage offered in calendar year 2015.

There is no change to Form 1094-C (

Form 1095-C ( has three changes to the instructions, all on page 2:

  1. Line 10. The telephone number to call with questions can also be used to report information errors on the form and ask that they be corrected.
  2. Line 14. Explanation that coverage reported does not include coverage offered through a multiemployer plan due to membership in a union.
  3. Line 14. Code 1A removed the dollar value to report coverage providing minimum value of self-only coverage, employee contributions equal to or less than 9.5% of the 48 contiguous states single federal poverty line versus equal or less than $1,108.65.

The instructions for Forms 1094-C ( and 1095-C ( include new information about these topics:

  • The Qualifying Offer Method and transitional relief for 2015
  • Multiemployer arrangements
  • Reporting COBRA coverage
  • Reporting coverage for individuals who have both medical coverage and a Health Reimbursement Arrangement (HRA)
  • Employees who have TRICARE or Veterans coverage
  • Counting the total number of employees per month on the 12th day of the month (as well as other days previously announced)


Form 1094-B ( has no changes.Form 1095-B ( now allows insurers to include only the last four digits of their Employer Identification Number (EIN).Changes to the Instructions for Forms 1094-B ( and 1095-B ( include:

  • Copies of Form 1095-B provided to individuals may include only the last four digits of Social Security Numbers (SSNs) or EINs. Forms filed with the IRS must include the complete numbers.
  • SSNs may be left blank if the individual does not have a SSN.
  • The instructions provide information about what to report for an individual who has more than one type of Minimum Essential Coverage.
  • Beginning in 2017 (for 2016 coverage), insurers must report catastrophic health plan coverage sold through the Marketplace. Reporting this coverage is optional but encouraged in 2016.
  • Clarification that insurers must identify employers that sponsor coverage through an association or MEWA but not multiemployer plan.

More information can be found at: