In January employers traditionally issue tax documents to their employees for the previous year.  Many employers who offer group health insurance to employees are confused about when and which Obama Care (ACA) forms they must submit to the IRS and to their employees.  The good news is that in July, 2013 the IRS issued Notice 2013-45 which gave large employers “transitional relief” from the “shared responsibility” penalties.   The IRS requires “Applicable Large Employers” (ALE) to file this information beginning in 2016 for the 2015 tax year.

Form 1095-C is a requirement of section 6056 of the Tax Code. This page on the IRS website describes how employers can comply with Section 6056: Questions and Answers on Reporting of Offers of Health Insurance Coverage by Employers (Section 6056)

Specifically, you should see question #2.  Below I bolded the IRS statement that the reporting requirements do not apply for 2014:

  • 2.  When do the information reporting requirements go into effect?

The information reporting requirements under section 6056 are first effective for coverage offered (or not offered) in 2015.  An ALE member must file information returns with the IRS and furnish statements to employees beginning in 2016, to report information about its offers of health coverage to its full-time employees for calendar year 2015.

Notice 2013-45 provides transition relief for 2014 from the section 6056 reporting requirements and the section 6055 reporting requirements for health coverage providers and, thus, the section 4980H employer shared responsibility provisions as well. Accordingly, neither the reporting requirements nor the employer shared responsibility provisions apply for 2014.  The transition relief applies to all ALE members including for-profit, non-profit, and government entity employers.  However, in preparation for the application of the employer shared responsibility provisions beginning in 2015, employers and other affected entities may comply voluntarily for 2014 with the information reporting provisions and are encouraged to maintain or expand coverage in 2014.  Returns filed voluntarily will have no impact on the tax liability of the employer.  For more information about voluntary filing in 2015, including the requirements for filing electronic returns, see