Important ACA Informational Reporting Deadline Update

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At the start of each year, Applicable Large Employers (ALEs), and small employers with self-insured plans, are required by the Affordable Care Act (ACA) to provide full time employees with Form 1095-C, and the IRS with Form 1094-C. For calendar year 2021, the IRS requires Form 1095-C to be provided to employees by March 2, 2022, thanks to an automatic extension recently granted by the IRS. However, be aware that the State of California imposes a different deadline – January 31, 2022. Read more to learn why.

An Applicable Large Employer (ALE) is one that had an average of 50 or more full time employees in the preceding calendar year. Hours of service of full time equivalent (e.g. part time employees) are also considered for determining ALE status. Companies with multiple business units connected through common ownership must combine employee totals due to IRS controlled group rules.

Beginning in 2020, California imposed a health insurance mandate on all citizens and required filing forms 1095-C and 1094-C with the Franchise Tax Board in order to enforce the mandate. Self-insured employers provide the filing directly, and fully insured employers have their filing completed by their insurance carrier. However, the State filing instructions mandate that 1095-C forms be provided to employees no later than January 31 – earlier than the current IRS deadline. Therefore, although the IRS has granted an extension to provide Forms 1095-C to employees, the State of California stills requires forms be provided by January 31. 

For further information regarding California ACA informational reporting requirements refer to the Franchise Tax Board webpage here: https://www.ftb.ca.gov/file/business/report-mec-info/index.asp.  

Specific Franchise Tax Board filing instructions (updated Feb 2021) for forms 1095-C and 1094-C can be found here: https://www.ftb.ca.gov/forms/2020/2020-3895c-publication.pdf.  

This information is general and is provided for educational purposes only. It is not intended to provide legal advice. You should not act on this information without consulting legal counsel or other knowledgeable advisors.