Employer’s Guide to ACA 1094/1095 Reporting for 2018

Employer’s Guide to ACA Reporting: A Review of the Forms and Instructions for 2018

Download the guide for instructions, sample forms, penalty descriptions for non-compliance, and coding data.

This guide reviews the 2018 forms and instructions and notes relevant changes from 2017. It also addresses IRS guidance on the solicitation of social security numbers (“SSNs”) or taxpayer identification numbers (“TINs”) and the treatment of cash “opt-out” payments for reporting purposes. It also provides guidance for employers that receive Letter 226J, Notice of a proposed Employer Shared Responsibility Payment, or Letter 5699, Request for ACA Reporting Forms.

The reporting requirements are complex, due in part to how the health care reform law was drafted. The Affordable Care Act added two sections to the Internal Revenue Code: Sections 6055 and 6056. The sections are found next to each other in the Code; however, they apply to different types of entities. Section 6055 applies to providers of health insurance, such as health insurance carriers and employers that sponsor self-insured plans. Section 6056 applies to “applicable large employers” or “ALEs”, which are employers with 50 or more fulltime equivalent employees in the prior calendar year.

To further complicate things, the reporting forms come in two different “series” – the B-Series and the C-Series forms. Employers may use either or both sets depending on their company size and whether their group health plan is self-insured or fully insured. Our goal with this guide is to provide some clarity and best practices for employers.


The information provided above is not, is not intended to be, and shall not be construed to be, either the provision of legal advice or an offer to provide legal services, nor does it necessarily reflect the opinions of the agency, our lawyers or our clients. This is not legal advice. No client-lawyer relationship between you and our lawyers is or may be created by your use of this information. Rather, the content is intended as a general overview of the subject matter covered. This agency and Marathas Barrow Weatherhead Lent LLP are not obligated to provide updates on the information presented herein. Those reading this guide are encouraged to seek direct counsel on legal questions.

© 2018 Marathas Barrow Weatherhead Lent LLP. All Rights Reserved.