Applicable large employers (ALEs) are required to report information about the health coverage they offered, or did not offer to employees for 2022. ALEs are generally entities that employed 50 or more full-time and full-time-equivalent (FTE) employees in the prior calendar year. To meet the reporting requirement, the ALE must furnish Form 1095-C to the employee, or former employee, and file copies, along with Form 1094-C (transmittal), with the IRS, (draft- 1094/1095C Instructions).
Regardless of size, employers who sponsored a self-funded health plan (including level-funded) that provided minimum essential coverage in 2022, are required to report coverage information about enrollees. To meet the reporting requirement, the employer must provide Form 1095-B to the primary enrollee and file copies, along with Form 1094-B (transmittal), with the IRS, (draft- 1094/1095B Instructions). Self-funded employers, who also are ALEs, may use Forms 1095-C and 1094-C in lieu of Forms 1095-B and 1094-B.
Due Dates:
Submission to the IRS: Forms 1094-C, 1095-C, 1094-B, and 1095-B forms must be filed with the IRS by February 28th if filing on paper (or March 31 if filing electronically). Electronic filing is mandatory for entities required to file 250 or more 1095 forms.
Submission to employees: The IRS has now released final rules allowing an automatic 30-day extension, until March 2 (March 1 in a leap year), for furnishing employee forms (Forms 1095-B and 1095-C).