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ACA Reporting for 2022 - Large Group Employers

Deadlines for ACA reporting for plan year 2022 health coverage (generated in the 2023 tax year) are swiftly approaching. The IRS has released final forms for 1094-C and 1095-C. However, the IRS has yet to announce the final instructions for Forms 1094-C/1095-C (see table below).

Instructions for Forms 1094-C and 1095-C (Draft)

 Form 1094-C

Form 1095-C

In anticipation of final IRS confirmation, here are a few things you should note:

Who Is Required to Report?

1094-C and 1095-CApplicable 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 automatically extended from January 31, 2023, to March 2, 2023. Thus, no additional extensions will be granted.

No Extension for Filing Returns With the IRS

The automatic extension does not apply to filings with the IRS. The deadlines will be:

  • February 28, 2023, for paper filings

  • March 31, 2023, 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.
*Employers submitting 250 or more 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 19, 2022. Reports will be posted to the secure Employers portal of our website. Details on how to use the reports and the report contents will be discussed in a future communication.


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