IRS Releases Final Employer Reporting Forms and Instructions

Friday, February 13, 2015 @ 01:02 PM

The Internal Revenue Service (IRS) released final forms and instructions for reporting on individual and employer mandates. The instructions and forms will be used by applicable large employers and employers with self-insured plans.

The Final Rules on Minimum Essential Coverage (MEC) and Large Employer reporting were released in 2014. The first reporting is required in early 2016 for the 2015 calendar year.


Plan Type / Employer Size Less Than 50 FTEs ALE’s
Fully Insured No Employer Reporting 1094-C and 1095-C
Self Insured 1094-B and 1095-B 1094-C and 1095-C1
No coverage No Employer Reporting 1094-C and 1095-C
  1.  ALE’s can use a single combined form for 6055 and 6056 reporting

Required Forms

There are two forms required for each set of information being reported: 1) a transmittal form that serves as a cover letter; and 2) forms providing data on either the individual or employer mandate, or both for self-insured employer sponsors.

  • 1094-C  Transmittal of Employer-Provided Health Insurance offer and coverage information returns

1094c Draft Form

  •  1095-C  Employee-provided Health Insurance offer and coverage

1095c Draft Form

IRS Instructions – “What the Instructions Cover”

The instructions provide an overview of why the forms/reporting are required. They also cover basic information including:

  • who must complete the forms
  • how the transmittal forms need to accompany their respective 1095-B or 1095-C Forms
  • where to mail paper forms; details for filing electronic forms are expected when the IRS posts Publication 5165
  • specific line by line instructions
  • general directions for contact person, signature on form and phone number
  • definitions of various terms used in reporting data
  • minimum guidance on multi-employer arrangements
  • transitional relief for off-calendar year plans


Instructions for Filing

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