Preparing for Large Employer Information Reporting

Because information reporting was voluntary for calendar year 2014, large employers are required to report health coverage information for the first time in early 2016 for calendar year 2015.

Internal Revenue Service (IRS) Publication 5196 provides guidance regarding the requirement under Health Care Reform that large employers (generally those with 50 or more full-time employees, including full-time equivalents) report information to the IRS and to their employees about their compliance with the employer shared responsibility provisions (“pay or play”) and the health care coverage they have offered, using new IRS Forms 1094-C and 1095-C (referred to as “section 6056 reporting”).


Publication 5196 provides a list of information that large employers will need to begin compiling to fill out the forms:

Form 1094-C
Large employers will need the following information to fill out this form:

  • Identifying information for the organization.
  • Information about whether the employer offered coverage to 70% of its full-time employees and their dependents in 2015. (After 2015, this threshold changes to 95%.)
  • Information for the “authoritative transmittal.”* This information includes:
    • The total number of Forms 1095-C the employer issued to employees.
    • Information about members of the aggregated large employer group, if any.
    • Full-time employee counts by month.
    • Total employee counts by month.
    • Whether the employer is eligible for certain transition relief.

*Because an employer may choose to file multiple Forms 1094-C, one of the Forms 1094-C must be designated as the “authoritative transmittal” that reports aggregate employer-level data for the employer. There must be only one authoritative transmittal filed for each employer.

Form 1095-C
Large employers will need the following information to fill out this form:

  • Which employees are considered full-time employees for each month.
  • Identifying information for the employer and its employees, such as names and addresses.
  • Information about the health coverage offered by month, if any.
  • The employee’s share of the monthly premium for lowest-cost self-only minimum value coverage.
  • The months the employee was enrolled in the employer’s coverage.
  • The months the employer met an affordability safe harbor with respect to an employee and whether other transition relief applies for an employee for a month.
  • If the employer offers a self-insured plan, information about the covered individuals enrolled in the plan, by month.


The guidance also includes a glossary of terms, an explanation of the new Forms 1094-C and 1095-C, and a list of certain information that large employers need to track for each month in 2015.

For additional questions or information contact a benefit specialist or consultant with Ventris.  We have the resources to help you prepare.