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Reminder: ACA Employer Reporting Requirements
Legislation signed by President Biden in December 2024 impacting the ACA employer reporting requirements under Sections 6055 and 6056 remains in effect for the 2025 reporting year. These changes were designed to streamline the reporting process for employers and include:
1. Form 1095 Distribution Requirements:
Employers are no longer required to automatically distribute Form 1095-C or 1095-B to individuals to meet distribution requirements. Instead, employers must take the following actions:
- Post a notice that is “clear, conspicuous, and accessible” with additional guidance to be provided on how to fulfill this notice requirement.
- Distribute the forms upon request by the individual, no later than March 2nd or 30 days after the request.
2. Reporting for Self-Funded Plans:
Employers reporting self-funded group health plan coverage for spouses and dependents may now use the individual’s date of birth in place of the tax identification number (TIN) when the TIN is unavailable. This adjustment removes the prior requirement to establish reasonable cause before utilizing the date of birth.
ACA Overview of Reporting Rules:
Attached below is an ACA Compliance Overview document summarizing the reporting rules under Code Sections 6055 and 6056. This is a valuable guide that includes relevant requirements, deadlines, resources and more.
Click below to download the overview:
Employer Reporting of Health Coverage Code Sections 6055 and 6056
The table below is a brief overview of some key reporting guidelines.
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6055/6056 Reporting Guidelines |
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6055 |
6056 |
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All health insurance plan issuers (insurance company) and all employer plan sponsors that provide health coverage |
Employers with an average of 50 or more full-time employees, including full-time equivalent employees, during the preceding calendar year |
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Reported By |
Fully Insured Plans: The insurance company responsible
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Fully Insured Plans, Self-Funded, and Level-Funded Plans for ALE Employers: Employer responsible Click below for assistance determining your ALE status: |
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2025 Required Forms |
Form 1095-B |
Form 1095-C |
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Form Instructions |
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Reporting Deadlines |
March 2, 2026 – to IRS if an employer is reporting on paper (available for groups of 9 or less) March 31, 2026 – to IRS if an employer is reporting electronically (required for groups of 10 or more) |
March 2, 2026 – to IRS if an employer is reporting on paper (available for groups of 9 or less) March 31, 2026 – to IRS if an employer is reporting electronically (required for groups of 10 or more) |
The tables below are designed to help employers understand what their reporting responsibilities are, under IRC Section 6055 and/or IRC Section 6056.
The tables only show group sizes and the types of coverage funding arrangements, where employer reporting is required. If the tables do not include your group size or coverage funding arrangement, then you are not required to report.
Fully Insured Groups |
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Carrier |
What the Carrier Provides |
What the Employer NEEDS To Do |
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Blue Cross and Blue Shield of Minnesota |
BCBSMN will file 1095-Bs and 1094-Bs with the IRS Forms 1095-B are mailed to members |
N/A – Carrier completes |
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Blue Cross and Blue Shield of Nebraska |
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N/A – Carrier completes |
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HealthPartners of Minnesota |
HealthPartners will file 1095-Bs and 1094-Bs with the IRS Members can request 1095-Bs from HealthPartners by contacting Member Services at 952-883-5000 |
N/A – Carrier completes
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Medica |
Medica will file 1095-Bs and 1094-Bs with the IRS Forms 1095-B are available to members upon request. Requests can be made by submitting the Contact Form found on medica.com |
N/A – Carrier completes |
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UnitedHealthcare |
UHC will file 1095-Bs and 1094-Bs with the IRS 1095-Bs are posted to members’ online portals |
N/A – Carrier completes |
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Carrier |
What the Carrier Provides |
What the Employer NEEDS To Do |
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Aetna |
Aetna will file 1095-Bs and 1094-Bs with the IRS on behalf of groups Members can pull the reports directly from the member website |
N/A – Carrier completes |
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Allstate / Nationwide |
Notifications are sent via email to employers |
File 1095-Bs and 1094-Bs with the IRS; Send 1095-Bs to members upon request Our recommended solution: 1095b-ezfile.com |
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Blue Cross and Blue Shield of Nebraska |
OCI will send over a member report from BlueCross BlueShield |
File 1095-Bs and 1094-Bs with the IRS; Send 1095-Bs to members upon request BCBSNE’s preferred vendor: 1095b-ezfile.com |
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HealthPartners of Minnesota |
HealthPartners, in collaboration with ACAPrime, will file 1095-Bs and 1094-Bs with the IRS Members can request 1095-Bs from HealthPartners by contacting Member Services at 952-883-5000 |
N/A – Carrier completes |
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Medica |
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File 1095-Bs and 1094-Bs with the IRS; Send 1095-Bs to members upon request Our recommended solution: 1095b-ezfile.com |
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UnitedHealthcare |
Reports are available to employers on www.uhceservices.com |
File 1095-Bs and 1094-Bs with the IRS; Send 1095-Bs to members upon request
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Applicable Large Employer Groups (Fully Insured & Self-Funded) |
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Carrier |
What the Carrier Provides |
What the Employer NEEDS To Do |
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Aetna |
Employers can pull the reports directly from the member website |
File 1095-Cs and 1094-Cs with the IRS; Send 1095-Cs to members upon request |
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Allstate / Nationwide |
Notifications are sent via email to employers |
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Blue Cross and Blue Shield of Nebraska |
OCI will send over a member report from BlueCross BlueShield |
File 1095-Cs and 1094-Cs with the IRS; Send 1095-Cs to members upon request |
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HealthPartners of Minnesota |
Fully Insured: HealthPartners will file 1095-Bs and 1094-Bs with the IRS Members can request 1095-Bs from HealthPartners by contacting Member Services at 952-883-5000 Self-Funded: Groups may reach out to ACAPrime directly via email or website if they’re interested in contracting them for assistance |
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Medica |
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File 1095-Cs and 1094-Cs with the IRS; Send 1095-Cs to members upon request |
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UnitedHealthcare |
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File 1095-Cs and 1094-Cs with the IRS; Send 1095-Cs to members upon request |
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If you have any questions, please contact our team via email at groupadmin@ociservices.com or give us a call us at (402) 330-8700.
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