Understanding Electronic Filing Requirements for ACA Information Returns

IRS Health Care Tax Tip 2015-74, November 12, 2015

To support Affordable Care Act regulations that were effective on January 1, 2015, the IRS will receive and process information returns reporting on individual’s health insurance coverage from insurance companies, self-insured companies, and large businesses and businesses that provide health insurance to their employees.

ACA information returns and transmittals are electronically filed through the ACA Information Returns system, also known as AIR. Non-ACA information returns can be electronically transmitted through the Filing Information Returns Electronically system, also known as FIRE.

ACA Forms 1094-B,1095-B,1094-C, and 1095-C are classified as information returns under the Internal Revenue Code which provides that any person, including a corporation, partnership, individual, estate, or trust, who is required to file 250 or more information returns, must file such returns electronically. The 250 or more information return requirement applies separately for each type of return and separately to each type of corrected return.

All filers are encouraged to file information returns electronically even if they file less than 250 information returns.

If a corporation with several branches or locations uses the same EIN, the corporation must aggregate the total volume of returns to be submitted for that EIN and apply the filing requirements to each type of return.

Issuers should retain a copy of information returns or have the ability to reconstruct the data for at least three years from the reporting due date.

AIR accepts the following information return transmittals and documents:

Form 1094-B, Transmittal of Health Coverage Information Returns
Form 1095-B, Health Coverage
Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
Form 1095-C, Employer-Provided Health Insurance Offer and Coverage

AIR will process each submission and provide a status with detailed acknowledgement for the transmitter.

Generally, the Form 1095-B and 1095-C will be submitted with their associated Form 1094-B and Forms 1094-C transmittals. In certain circumstances, the Form 1094-C can be submitted alone.

More Information

The IRS will hold the next live ACA AIR webinar for Transmitters, Software Developers, and Issuers/Payers on November 17, 2016 at 3 PM ET.

IRS Health Care Tax Tip 2015-51 provides links to in depth recorded webinars on the information reporting requirements.

The ACA Information Returns (AIR) Program webpage can be accessed by typing AIR in the IRS.gov search window.

Information about these and other tax provision can be found at IRS.gov/aca.

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