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ACA Reporting for 2021 - Large Group

The deadlines for ACA reporting on plan year 2021 health coverage are swiftly approaching. The IRS has released final forms & instructions for 1094-C and 1095-C (see table below). 

Instructions for Forms 1094-C and 1095-C

Form 1094-C

Form 1095-C

In preparation for the form filings, here are a few things you should note:

Who Is Required to Report?

1094-C and 1095-C: Applicable large employers (generally those with 50 or more full-time employees, including full-time equivalents or FTEs) will use Forms 1094-C and 1095-C to report information to the IRS and to their employees about their compliance with the employer-shared responsibility provisions (“pay or play”) and the health care coverage they have offered. Employers subject to both reporting provisions (generally self-insured employers with 50 or more full-time employees, including FTEs) will satisfy their reporting obligations using the C Forms. 

What Are the Deadlines?

The deadlines are as follows:

Deadline for Furnishing Statements to Individuals

  • The deadline for furnishing Forms 1095-C to individuals has been extended from January 31, 2022 to March 2, 2022. The IRS has proposed regulations that would make this a permanent 30-day automatic extension for furnishing the forms to individuals.

No Extension for Filing Returns with the IRS

  • The relief does not apply to filings with the IRS. The deadlines will be:

    • February 28, 2022, for paper filings

    • March 31, 2022, for electronic filings*

      Filers may extend these deadlines by application to the IRS. Any employer who would like to file electronically should refer to the IRS for more information on the AIR Program, which requires at least 30 days for testing for first-time users.

*Please note that employers submitting more than 250 forms must file electronically.

How Will MedCost Assist Clients?

MedCost is generating reports for our clients that will be available as early as the week of December 20, 2021. Reports will be posted to the secure Employers portal of our website. Details on the report contents and how to use the reports will be discussed in a future communication.

As always, MedCost is here to assist you in any way we can with ACA reporting requirements. If you have any questions, please contact your Account Manager or MedCost Compliance at [email protected].