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Friday, 18 October 2019 12:13

Heads Up - Line Up Your Vendor Now for Affordable Care Act Requirements

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Despite numerous attempts over recent years to repeal The Affordable Care Act (ACA), the requirement for certain reporting is still the law of the land. The deadline of January 31st, 2020 to distribute 1095-Bs or 1095-Cs to employees is fast approaching, and vendors get booked up early to complete the filings. Are you ready, and do you have your reporting vendor lined up yet?

Reporting is required of Applicable Large Employers (ALEs) with 50 or more full-time equivalents, and any employers who use partially self-funded plans. In past years, the deadlines for the 1095 forms have been extended, but for now the original due date of January 31, 2020 remains for reporting 2019 coverage.

Employers are also responsible for filing copies of Form 1094-B and -C and 1095-B and -C forms with the IRS by the following deadlines:

  • Filing by Paper: February 28, 2020

  • Filing Electronically: March 31, 2020

As a quick reminder of the requirements, check out this chart:

IRS Code

Which employers it applies to

Form requirements

Due Dates

Section 6055

Self-funded employers of any size

1094-B to IRS

1095-Bs to employees and IRS

2/28/20 if filing by paper,
3/31/19 if filing electronically


Section 6056

Applicable Large Employers (ALEs) with 50+ employees

1094-C to IRS

1095-Cs to employees and IRS

2/28/20 if filing by paper,
3/31/19 if filing electronically


Section 6055 and 6056 of the ACA requires these reports to be sent to all employees and their dependents that received or were offered medical coverage at any time in 2019. These forms help the IRS determine if minimum essential coverage is being offered under the employer mandate. For instructions on how to fill these forms out, you can go to https://www.irs.gov/forms-pubs/about-form-1095-c.

Most organizations do not typically collect Social Security Numbers for their employees’ dependents, however, this is a necessary item in completing these forms. If you haven’t already collected dependent SSNs, how do you go about getting them quickly? In the age of identity theft, you may have employees that are reluctant to supply them. While there is no model language provided by the IRS to obtain them from employees, we suggest the following language:

“___Group Name___ is required by the IRS to provide important tax forms to employees and their dependents each year. To complete our obligation, we request that you provide the SSNs for your dependents ASAP to Human Resources.”

Here are some tips for obtaining the information you need moving forward:

  • Request the SSNs of all dependents at the time of hire of an employee as part of their required paperwork. (There are other reasons you may need a dependent’s SSN, such as the Medicare Data Match program).

  • Schedule a year-end clean-up project to collect any missing SSNs. Think about any marriages or births during the past year, or other instances where you may not have new dependent SSNs.

  • You don’t need to request an SSN from a terminated EE for the purposes of ACA reporting.

  • If you cannot obtain a dependent’s SSN, you can use the date of birth instead. You may need to prove to the IRS that you made at least three attempts to obtain the dependent’s SSN.

If your organization needs some guidance to complete these forms, contact your Fall River Client Manager with any questions. We’re here to help!

Read 1586 times Last modified on Monday, 14 September 2020 10:31