The Affordable Care Act’s (ACA) individual mandate for employees was officially repealed on January 1, 2019. However, Congress did not repeal the ACA requirements for employers. Applicable large employers (ALE) with 50 or more employees are still required to provide access to healthcare to employees and meet annual reporting requirements.
To avoid year-end scrambling, employers should begin preparing for ACA reporting now. This includes verifying the organization’s ALE status, confirming employee eligibility and offers of coverage, and verifying ACA codes with the employer’s broker.
Dates for 2019 reporting, submitted in 2020, appear below, along with last year’s deadlines for reference. The 1095-C due date to employees was extended in 2019 but isn’t expected to be in 2020.
| ACA Reporting Forms | 2018 Tax Year Deadlines (forms filed in 2019) | 2019 Tax Year Deadlines (forms filed in 2020) |
| 1095-C due to employees (postmarked if mailed) | March 4, 2019 | January 31, 2020 |
| 1094-C and 1095-C due to IRS if paper filing | February 28, 2019 | February 28, 2020 |
| 1094-C and 1095-C due to IRS if electronic filing | April 1, 2019 | March 31, 2020 |
For more information, visit the Internal Revenue Service’s (IRS) ACA resource page for employers.
