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Affordable Care Act Reporting Requirements

July 15, 2015


The recent Supreme Court decision left unchanged the provision that Applicable Large Employers, defined as employers (and affiliated groups of employers) that employed on average 50 or more Full Time Equivalent Employees during the prior calendar year (2014) are subject to a new reporting requirement for the current calendar year (2015).

In a manner similar to the W-2 process, Applicable Large Employers will be required to provide each full time employee with certain information (by month) on Form 1095-C regarding the health insurance provided (or not provided) for calendar year 2015. This filing will be due by January 31, 2016.

As one might expect, applying the new rules may not be a simple task. There are a number of potential issues that may affect an Employer’s requirement to file such as:

  • Calculating the average number of Full Time Equivalent Employees
  • Impact of Seasonal Employees on the calculation
  • Determination of inclusion in an affiliated group
  • The transitional rule using “6 months in 2014” to determine 2015 filing requirements


Gathering the information necessary to determine the requirement to file as well as the information to be furnished if filing is required may involve substantial time and effort.

To avoid penalties for late filing or failure to file, we encourage you to determine if you are an Applicable Large Employer and if so, begin the process of gathering necessary information to complete Form 1095-C.