1. ACA Employer Reporting -Data Collection and Action Items
ACA requires employers provide a completed 1095C report (see attached) to each full time employee working at
least 30 hours/week by January 31, 2016. The 1095C report will include employee identifying information (name,
address, social security number) in addition to the data listed below. Copies of the 1095C reports must be filed
with the IRS as well- along with Transmittal report 1094C (see attached) by February 28, 2016, or March 31, 2016
for electronic filers. Note, employers with at least 250 1095C reports are required to file electronically with the
IRS. Also, the social security number can be truncated on the 1095C form sent to the employee, but not on the
copy sent to the IRS.
The purpose of the reports is for the IRS to monitor and enforce the employer “play or pay” rules. Employers with
100 or more employees must offer affordable coverage that provides minimum value beginning with their renewal
date in 2015. Employers that do not satisfy the play or pay rules could be subject to a penalty.
Importantly, although employers with 50-99 full time employees are not required to comply with the ACA play or
pay rules until their renewal date in 2016, these employers are still subject to the reporting requirements.
Employers with 50-99 employees must also provide a report to their full time employees with copies to the IRS in
2016.
The 1095C and 1094C reports require 2015 monthly data be provided. The monthly data that needs to be
captured is listed below.
• Employee name, address, date of hire and social security number
• Number of full time employees each month
• Number of total employees each month
• The months during the calendar year that Minimum Essential Coverage was available (employer coverage
is MEC coverage)
• The months an employee was not offered coverage due to a waiting period, the employee was not full
time or not yet employed.
• Employee contribution toward lowest cost individual only health plan
• For self- insured employers (Part III of 1095C): name and SSN (DOB if SSN not available) for each covered
individual and the months they were covered.
Employers will also report if the health coverage offered provides minimum value as well as report any safe harbor
rules (if applicable).