Which ACA Form Do I Need? 1095-B vs. 1095-C

Both Forms 1095-B and 1095-C are for Affordable Care Act reporting, but you may find yourself asking: which ACA form do I need? There are some key differences in each form, so we have created this guide to help you decide which you need in order to report your data.

What is Form 1095-B?

Form 1095-B is distributed by insurers and small employers who offer self funded coverage to their employees. The form provides information regarding the individuals covered, such as their name, type of coverage, and duration of coverage.

What is Form 1095-C?

Form 1095-C is distributed to eligible employees by employers who have 50 or more full-time + full-time equivalent employees on average (also known as ALEs). This form provides information regarding the employees such as their name, whether they accepted the coverage, and any dependents covered beneath them.

Which ACA form do I need?

Consider which of the following categories apply to you for the reporting tax year:

Small Group. Less than 50 full-time + full-time equivalent employees.
Large Group. 50 or more full-time + full-time equivalent employees.

Fully-Insured. Healthcare expenses paid by insurer.
Self-Insured. Healthcare expenses paid by the employer.

If you are a small group and offer a fully-insured plan, the insurer will file Form 1095-B. The employer is not responsible for reporting.

If you are a small group and offer a self-insured plan, the employer is responsible for filing and distributing Form 1095-B.

If you are a large group and offer a fully-insured plan, the insurer will file Form 1095-B. However, the employer is responsible for filing and distributing Forms 1095-C with sections I and II of the form completed.

If you are a large group and offer a self-insured plan, the employer is responsible for filing and distributing Form 1095-C with all sections of the form completed.

Forms 1095-B and 1095-C are filed with the IRS using transmittal Forms 1094-B and 1094-C, respectively.

What if I had 50 or more full-time equivalent employees for only part of the year?

In order to determine if you are required to report as a large group (also known as an Applicable Large Employer or “ALE”), add the total number of full-time and full-time equivalent employees for each month of the entire year and divide that total by 12.

If the number equals 50 or more, you are considered an ALE and should file the appropriate 1095 form.

What if there are two EINs that are small groups under common ownership?

An ALE may be a single employer or may consist of a group of related employers (such as parent and subsidiary entities or other related/affiliated entities), called an Aggregated ALE Group. These filers would use Forms 1094-C and 1095-C for their filings.

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