The Employer Shared Responsibility provisions affect companies with 50 or more full-time employees or an equivalent of part-time or seasonal workers. These companies are called Applicable Large Employers, or ALEs. 2015 was considered a transition year as everyone got used to the new normal for workplace health plans.
Employers use 2018 to establish a baseline for reporting workplace health insurance coverage that it offers to its workers. The most important forms used to connect worker, employer and the government are Forms 1094-C and 1095-C. These forms report health care coverage offered to employees as well as enrollment information for those that have opted into their company’s health insurance program.
Forms 1094-C and 1095-C are due in early 2021 for 2020. Form 1095-C is the workhorse form for health insurance. All employees eligible for health care in a company should receive a 1095-C. It doesn’t matter if a worker doesn’t participate in the plan, since the form shows the worker what choices are available through the company’s plan. The worker can then look at other health insurance options, using the 1095-C to compare details such as:
- general and specific points of coverage available
- the cost of each health care option
- what part of the year coverage is available through each plan
The IRS also receives a copy of the 1095-C, along with Form 1094-C.
Each 1095-C covers an individual worker and is submitted to both the worker and the IRS. The 1094-C goes only to the IRS and it summarizes all of the 1095-C forms issued to eligible workers. The 1094-C acts as a "cover-sheet" for all if the 1095-C forms going to the IRS with information such as:
- number of 1095-C forms included in the company’s submission
- number of employees in the company
- information about the company such as address, contact information, employer identification number and the name of the contact person in the company
The two forms combine to give the IRS the information it needs to administer the terms of the Affordable Care Act. The forms help the IRS determine:
- which companies comply with ACA requirements
- what health care options are available to individuals and whether they qualify for financial assistance
Employers that offer health plans but have fewer than 50 full-time or full-time equivalent employees are still required to report using forms 1094-C and 1095-C.