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ACA Update - Reporting Requirements & CSR Subsidies

Posted on September 20th, 2018

2018 ACA Reporting Requirements

The Internal Revenue Service (IRS) has released draft versions of the forms and instructions for the 2018 reporting year. The reporting, which is required under the Affordable Care Act (ACA), helps the IRS enforce the Individual Mandate, Employer Mandate and verify subsidy eligibility for individuals who obtain coverage through the Health Insurance Marketplace.

In general, employers with 50 or more employees must complete Forms 1094-C and 1095-C. Smaller employers with self-insured plans and insurance carriers providing fully-insured coverage must complete Forms 1094-B and 1095-B. The forms must be submitted to the IRS by February 28, 2019 if filing manually and by March 31, 2019 if filing electronically. However, copies of the forms must be provided to employees and covered individuals by January 31, 2019.

Copies of the draft forms and instructions have been provided below. Final versions are expected to be released later this year.

Draft 1094-B

Draft 1095-B

Draft B Form Instructions

Draft 1094-C

Draft 1095-C

Draft C Form Instructions


CSR Subsidy Update

A court has ruled that the federal government violated its obligations under the Affordable Care Act (ACA) when it discontinued making payments to insurance carriers for cost-sharing reduction (CSR) subsidies. CSR subsidies are available to eligible individuals with household incomes up to 250% of the Federal Poverty Level (FPL). These subsidies help reduce out-of-pocket costs for eligible individuals who obtain coverage through the Health Insurance Marketplace, and they are paid to insurance carriers.

The Trump administration discontinued making CSR subsidy payments after October of 2017 because Congress never appropriates funds for this purpose. However, last year, a different court refused to require the federal government to make CSR subsidy payments, and the case was later dismissed. As a result, there continues to be uncertainty about if or when the CSR subsidy payments will be restored.


Do you have a question about ACA
employer reporting or CSR subsidies?

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