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2018 ACA Reporting

The IRS has released the draft 2018 forms for the Affordable Care Act (ACA) reporting under the 6055 and 6056 Internal Revenue Code.


  • 1094-C and 1095-C were released on July 11, 2018 will be used by Applicable Large Employers (ALEs) to report under Section 6056. For self-insured plan sponsors they will continue to use combined reporting under Sections 6055 and 6056

  • 1094-B was released on July 3, 2018 and will be used by entities (carriers) under Section 6055.

  • The 2018 draft forms are substantially similar to the final 2017 versions of the forms.

  • The “Plan Start Month” box in Part II of Form 1095-C continues to be optional for 2018 reporting.

  • Additional clarifications may be included in the draft instructions.

  • Instructions for the draft versions have not yet been released.

Key Dates

  • January 31, 2019 - Individual statements for 2018 must be furnished by January 31, 2019.

  • February 28, 2019 - IRS returns for 2018 must be filed by February 28, 2019 (April 1, 2019, if filed electronically, since March 31, 2019, is a Sunday)

Next Steps

Employers should become familiar with these forms and the Key Dates for compliance for the 2018 calendar year. Keep in mind that the 2018 draft instructions for these forms may include additional changes or clarifications, once released. Also, the IRS may make additional changes to these forms before releasing final 2018 versions.


1095-C - Draft Form

Need Further Information

Contact AJM Associates at (248) 778-6070 or via email at

This ACA Compliance Bulletin is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. Material posted on this website is for informational purposes only and does not constitute a legal opinion or medical advice. Contact your legal representative or medical professional for information specific to your needs.

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