2023 ACA Reporting Deadlines for Forms 1094/1095

Posted on February 2, 2023

Applicable large employers (ALEs) — those that had an average of 50 or more full-time employees or full-time equivalents during the 2022 calendar year must report whether they offered eligible employees affordable health coverage that provides minimum essential coverage and meets the minimum value threshold using Form 1095-C.

Small employers with fewer than 50 full-time employees are exempt from most ACA reporting requirements. However, self-insured small employers must comply with this reporting requirement using Forms 1095-B and 1094-B.

2023 filing deadlines for 2022 coverage are as follows:

ACA RequirementDeadline
1095 forms delivered to employeesMarch 2, 2023
(automatic extension from Jan 31)
Paper filing with the IRSFebruary 28, 2023
Electronic filing with the IRSMarch 31, 2023

The IRS has provided this helpful checklist for ACA Reporting:

  • Determine ALE status for 2020 based on 2019 data. Identify full-time employees based on the ACA’s definition of full time (averaging 30 hours of work or more per week during a month), considering special classifications such as staffing employees, independent contractors, temporary or short-term employees, and even interns.
  • Assess whether the monthly measurement method or look-back measurement method to determine full-time status is best, based on the nature of the company’s workforce. Update plan documents and summary plan descriptions, if necessary, for the measurement method selected.
  • Select the appropriate safe harbor the company will use for the affordability calculation: W-2, rate of pay, or federal poverty line.
  • Make sure Social Security number request obligations are being fulfilled.
  • Check reporting obligations for non-ALEs that self-insure group health plans.
  • Review the instructions for required forms, noting changes from prior years.

For more information and to get the most current forms from the IRS click here.