Wipfli Alerts & Updates: Affordable Care Act (ACA) Reporting of 1095 Forms

January 28, 2016
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As you may know, the IRS issued guidance under IRS Notice 2016-4 that extended the due date for furnishing employees with a copy (by mail, in person, or electronically) of Form 1095-B or Form 1095-C to March 31, 2016. Normally these forms would be furnished by January 31 of the year following coverage. However, 2015 is a transition year, and the Form 1095-B or Form 1095-C may be delayed.

As a general rule, Form 1095-B is issued by the insurance carrier to the employee, spouse, and dependents for fully insured plans. Form 1095-B is also issued by employers with self-insured plans that have fewer than 50 full-time equivalents. Form 1095-C is issued by employers who are applicable large employers (ALE), defined as employers with 50 or more full-time equivalent employees. So it is possible for employees to receive one or a combination of these forms, or none at all, depending on their individual circumstances. If any individuals had health insurance through more than one employer during the year, they may receive a Form 1095-B or Form 1095-C from each employer.

The Forms 1095-B/C do not need to be attached to an individual’s tax return, so individuals are permitted to prepare their returns prior to receiving the forms. In addition, individuals are not required to amend their tax returns if the information they used to prepare their return is different from what is reported on the Form 1095-B/C they receive.  

When individuals receive the form, it should be kept with their 2015 tax information in case they should need to provide proof of whether they had health insurance through their employer. If you have any questions, please contact Pam Branshaw, Tom Krieg, Bob Buss, Keith Koszarek, or your Wipfli relationship executive.

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