ACA News & Publications

ACA Pathways: Employer Reporting Finalized

October 19, 2018

The Internal Revenue Service (IRS) has released final 2018 forms for reporting under Internal Revenue Code (Code) Sections 6055 and 6056. Final instructions for 2018 were also released.

  • 2018 Forms 1094-C and 1095-C are used by applicable large employers (ALEs) to report under Code Section 6056, as well as for combined Code Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.
  • 2018 Forms 1094-B and 1095-B will be used by entities reporting under Code Section 6055, including self-insured plan sponsors that are not ALEs.

The 2018 forms and instructions are very similar to the 2017 versions. Please note that the "Plan Start Month" box in Part II of Form 1095-C will remain optional for 2018.

Forms 1094-C and 1095-C are available on the IRS website here and here, respectively. Related instructions can be found here.

Forms 1094-B and 1095-B, and instructions, are available here, here, and here, respectively.

Filing Deadline

Individual statements for 2018 must be furnished by January 31, 2019, and IRS returns for 2018 must be filed by February 28, 2019 (April 1, 2019, if filed electronically, since March 31, 2019, is a Sunday).

According to the IRS, information returns under Sections 6055 and 6056 may continue to be filed after the filing deadline (both on paper and electronically). Employers that missed the filing deadline should continue to make efforts to file their returns as soon as possible.

Additional Resources

The IRS also previously released:

For More Information
For more information about this ACA Pathways or about any other health care reform-related provisions, please contact your Burnham Benefits consultant or Burnham Benefits at:

Burnham Benefits

Burnham Benefits does not engage in the practice of law and this publication should not be construed as the providing of legal advice or a legal opinion of any kind. The consulting advice we provide is intended solely to assist in assessing its compliance with the Patient Protection and Affordable Care Act and other applicable federal and state law requirements, and is based on Burnham Benefit’s interpretation of federal guidance in effect as of the date of this publication. To the best of our knowledge, the information provided herein, and assumptions relied on, are reasonable and accurate as of the date of this publication. Furthermore, to ensure compliance with IRS Circular 230, any tax advice contained in this publication is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting, marketing or recommending to another person any tax-related matter.

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