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May 2015 Issue


Us? When?! Learning About 1094C And 1095C Reporting For Self-Insured Employers

New Summary Of Benefits And Coverage Template Delayed Until 2016

Quick Poll – Review

May Quick Poll – Vote

Contact Information



If you're concerned about getting 1094C and 1095C reporting done pronto, worry not: These forms are not required to be filed in 2015 by any employer to report 2014 information. But you may want to consider using the time in preparation for the first required filing of these forms (which is filing in 2016 for 2015). If you wish, employers like you may voluntarily file in 2015 for 2014 numbers, in accordance with the proper forms and instructions. The practice may be worthwhile, uncovering current system shortfalls that may prevent prompt success.

Here is a quick review of the IRS Code and required actions:

What: The Affordable Care Act added section 6056 to the Internal Revenue Code, which requires applicable large employers (ALEs) to file information returns with the IRS and provide statements to their full-time employees about the health insurance coverage they offer. The information reporting requirements under section 6056 are first effective for coverage (or lack thereof) in 2015.

Who: An applicable large employer (ALE) member must file information returns with the IRS and furnish statements to employees beginning in 2016. This will report information about health coverage offered to full-time employees for calendar year 2015.

Note: An applicable large employer (ALE) is one that employed an average of at least 50 full-time employees on business days during the preceding calendar year. A full-time employee generally includes any employee who, on average, worked at least 30 hours per week. It also includes any full-time equivalents. For example, 40 full-time employees who worked 30 or more hours per week on average, plus 20 employees who worked 15 hours per week on average, are equivalent to 50 full-time employees. However, any employer that sponsors a self-insured health plan is required to report under section 6055, even if the employer has fewer than 50 full-time employees.

When: You don't need to do any reporting in 2015 unless you want a "practice run." Deadlines for 2016 are February 29 or March 31 (if filing electronically). But now is the time to develop appropriate procedures and ensure systems are in place to collect the data you need for the forms.

How: You may handle the filing yourself, or discuss the reporting requirements with a third party. For example, your payroll vendor may be able to offer software upgrades to help simplify data collection and form preparation. NIHP will provide whatever data we have available to help you submit accurate reports.

The chart below helps clarify 1094C and 1095C reporting guidelines:

Employer Size ALE Member Employer Health Plan Employer Files Forms 1095-B/1094-B Employer Files Forms 1095-C/1094-C
Small employer No None No No
Small employer No Insured No (insurer files forms) No
Small employer No Self-insured Yes No
Small employer treated as large (see ALE discussion) Yes None No Yes
Small employer treated as large (see ALE discussion) Yes Insured No (insurer files forms) Yes
Small employer treated as large (see ALE discussion) Yes Self-insured Generally, no* Yes
Large employer N/A None No Yes
Large employer N/A Insured No (insurer files forms) Yes
Large employer N/A Self-insured Generally, no* Yes

*Employers with non-employees enrolled in their self-insured health plans, such as directors, retirees and individuals on COBRA, can elect to report these non-employees on Forms 1095-B and 1094-B instead of Forms 1095-C and 1094-C.

Chart source: McGladrey.com


IRS instructions

IRS questions and answers

New information reporting requirements under the Affordable Care Act

IRS issues forms and instructions for ACA reporting


The federal government has delayed implementing proposed changes to the Affordable Care Act's Summary of Benefits and Coverage (SBC) until January 2016. This is a document that is typically produced by insurers for fully-insured employers and by TPAs for self-insured employers. NIHP produces this document on your behalf if we administer your self-insured employee health plan.

Most employers are pleased with the template's postponement, recommended by several major business organizations, since it provides them with more time to put an effective process in place.

Designed to help plan members better understand what their health insurance covers, the SBC template is being revised to:

  • Shorten the document.
  • Eliminate certain questions.
  • Update the Uniform Glossary.
  • Include information about the plan's status as providing minimum essential and minimum value coverage.
  • Add a coverage example that details the expenses a plan participant could expect to pay for emergency care.
  • Update SBC instructions and the example calculator.

Your takeaway: Enjoy the reprieve, but don't stop thinking about your SBC statements. A shortened version of the SBC will still need to be produced on behalf of your health plan next year. Let us know if you have any questions about the process.


DOL delays new SBC template

Summary of PPACA benefits deadline pushed back to 2016

Smart benefits: New SBC template delayed 'til 2016

A Quick Review of Last Issue's "Quick Poll"

In the January 2015 issue of E to E we asked readers, "Does your plan assess a surcharge for employees who smoke?" Specific survey results are noted in the chart, below.

January Quick-Poll Summary

May Quick Poll – Vote

Have you begun preparing for the required IRS 1094C and 1095C reporting yet?
(Click a response to vote. Answers are strictly anonymous.)

Then, visit the NIHP website to view this issue's quick poll results.

For more information contact us at:
(800) 723-0202 or NIHPCustomerService@fhn.org

Northern Illinois Health Plan

773 W. Lincoln Blvd., Suite 402, Freeport, IL 61032

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