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Navigating the Affordable Care Act: A Guide to Employer Mandates and Reporting Requirements

Enacted in 2010, the Affordable Care Act (ACA) stands as a cornerstone of comprehensive health care reform in the United States. The heart of its objective is to extend affordable health care coverage to a broader population. Among the key provisions within the ACA is the Employer Mandate, which places obligations on Applicable Large Employers (ALEs) to provide affordable health insurance with “minimum value” to their full-time employees.

Understanding the Employer Mandate:

Applicable Large Employers, defined as those with at least 50 full-time employees (including full-time equivalent employees) on average during the prior calendar year, are subject to the Employer Mandate. This mandate requires ALEs to offer affordable health insurance that meets minimum value standards to their full-time employees.

Although small groups with self-funded plans are exempt from the Employer Mandate, they are still required to complete ACA reporting to ensure compliance.

The Employer Mandate does not apply to small groups with fully insured plans, and they are not subject to ACA reporting.  However, these employers should keep in mind that other aspects of ACA may apply, such as W-2 reporting of employer sponsored coverage.

IRS Reporting Obligations:

To ensure transparency and accountability, employers are required to report to the IRS regarding the health coverage they offer to their employees. Failure to do so can result in significant penalties. Notably, the IRS no longer provides “good faith” penalty relief that was initially available when reporting was first required.

Who Needs to File What?

Applicable Large Employers with Fully or Self-Insured Plans:

  • Employer Mandate applies.
  • Required to file forms 1094-C and 1095-C.

Small Employers with Self-Insured Plans:

  • Employer Mandate does not apply.
  • Required to file forms 1094-B and 1095-B.

Small Employers with Fully Insured Plans

  • Employer Mandate does not apply.
  • Not subject to ACA reporting, but keep in mind that other requirements may apply.

Important Deadlines – Filing Electronically

Beginning with reporting for 2023, employers who file 10 or more tax forms in aggregate must file the returns electronically.

This count includes other returns (such as 1099s and w2s) which effectively removes the ability to file by paper for most employers.

IRS submission (1094 B and C) : April 1, 2024

Copies to Individuals (1095 B and C): March 1, 2024

An extension of 30 days is available if the employer requests an extension by filing Form 8809 on or before the normal filing deadline.

Navigating the Affordable Care Act and its associated mandates and reporting requirements can be complex, but it is crucial for employers to stay informed and compliant. As the IRS imposes strict penalties for non-compliance, taking proactive steps to understand the obligations and meeting the necessary reporting requirements is paramount. By staying abreast of the regulations and fulfilling reporting duties, employers contribute to the overarching goal of the ACA—ensuring accessible and affordable health care for a wider segment of the population.

This information is intended to be broad in scope and may not address every employer’s specific situation.  Please consult a tax or legal advisor for further guidance. 

About Henriott Group

Henriott is an independent Risk Management firm, located in Indianapolis and West Lafayette, dedicated to helping clients prevent, manage, and recover from critical incidents. Working in both public and private entities through effective risk management, risk financing, commercial insurance, employee benefits, human resources, crisis management, contingency planning, and crisis response.


Jennifer Hannen, Employee Benefits (765) 429-5006 | jhannen@henriott.com
Grace Pritchett, Communications (765) 838-8610 | gpritchett@henriott.com



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