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What Every HR Needs To Know - ACA Reporting 2019

Updated: Jan 9, 2019

The end of the year 2018 is fast approaching, which means that for every Human Resource department, ACA Compliance should be on their minds.

AJM Associates has put together this useful important ACA deadlines listing to help prepare for the 2018 tax reporting year in 2019. Baring any last minute changes from the IRS, below are the ACA deadlines to prepare for.

2019 Compliance Reporting

  • January 31, 2019 - Deadline to furnish Form 1095-C to employees

**********************************************************************************UPDATED: The IRS announced on November 29th the extension of the deadline for employer to furnish Form 1095-C and for insurance carriers Form 1095-B. The Extended Deadline is now March 4, 2019. The IRS has not extended the due date for the 2018 filing of Forms 1094-B, 1094-C, or 1095-C to the IRS. That deadline still remains the same as indicated below.


  • February 28, 2019 - If filing by paper - Deadline to file forms 1094-C/1095-C

  • April 1, 2019 - If filing electronically - Deadline to file forms 1094-C/1095-C

  • April 15, 2019 - TAX DAY, which means individuals will have to file their individual returns with the IRS and their returns should include their healthcare coverage on the returns for 2018.

Under the updated regulations for the ACA Individual Mandate Penalty, this has been reduced to $0 for 2019, but for 2018 and the upcoming tax filing a penalty still exists for not having qualified health care coverage.

What are the ACA Reporting Forms?

Form 1095-C - This form helps employees complete their individual tax return and provides them the details regarding their health coverage for the previous year. Employers are responsible for providing this form to employee by January 31, 2019 and for providing copies to the IRS no later than February 28, 2019 via paper submission or by April 1, 2019 via electronic submission. Employers are required to file Form 1095-C electronically, if they have 250 or more forms to file.


Form 1094-C - If you are considered an Applicable Large Employer (ALE) you are required to show proof of the employer's compliance with the Employer Shared Responsibility Mandate under the ACA through Code Section 6055 and 6056. Employers are to use Form 1094-C to report whether the employer offered affordable Minimum Essential Coverage (MEC) or not to eligible employees and what months, if not all that coverage was offered.


Forms 1094-B / 1095-B: These forms are required to be furnished by the Health Insurance Carrier to enrolled individuals on the Individual Market or Fully-Insured Small Group Market for groups with less than 50 Full-Time Equivalent (FTE) employees not subject to the Employer Shared Responsibility Mandate under the ACA. The employer does not provide to employee's these forms, rather they come from the Health Insurance Carrier and need to be post marked no later than January 31, 2019.


Penalty For Non-Compliance

A failure to file accurate and complete 1094-C forms by the deadline comes with a penalty of $250 per form penalty, but not to exceed $3 Million per year. A failure to file accurate and complete 1095-C forms by the deadline comes with a penalty of $500 per form penalty for employers.

Disclaimer: AJM Associates does not provide tax or legal advice. This information is not intended and should not be taken as tax or legal advice. Any tax or legal information in this notice is merely a summary of AJM Associates' understanding and interpretation of some of the current tax regulations and is not exhaustive. You should consult your tax advisor or legal counsel for advice and information concerning your particular situation before making any decisions.

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