Fully_Insured_IRS_Sections_6055_6056 FAQ - Affordable Care Act Reporting Requirements

Sep 20, 2026

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FAQ answering questions about ACA reporting under IRS sections 6055 and 6056 for applicable large employers and fully-insured plans. It explains who must report health coverage information to the IRS, employer size thresholds, when filing is required, and what tax forms (such as Form 1095-B and completed Form 1095-C, with possible substitute forms) are furnished to employees and how TINs are handled. It also describes shared responsibility payment rules when coverage is not offered.

LanguageEnglish

CategoryLetters

FormatPDF

Pages3

Reading Time1 min

AccessFree to download

FAQ (Frequently Asked Questions)

Sections 6055 and 6056 overview

Applicable Large Employer (ALE) and filing obligations

Forms provided for fully-insured employers

TIN collection and Form 1095-C Part III

Shared responsibility payment when coverage is not offered

FAQ (Frequently Asked Questions) Note: The Blue Cross and Blue Shield of Wyoming is not providing, and does not provide any legal or tax advice on the requirements of the Affordable Care Act (ACA), or any other federal or state law. These FAQs are not intended to provide any legal or tax advice, and may not be used to avoid any federal or state tax penalties. Guidance on specific requirements of the ACA and other federal laws are provided by the U.S. Department of Health and Human Services (HHS) and/or other agencies. The information provided reflects the Service Benefit Plan’s understanding of the most current information and is subject to change without further notice. If you have any specific questions about how these rules relate to you, please ask your legal and/or tax advisors. What is section 6055 and 6056? The Affordable Care Act created new reporting requirements whereby applicable large employers (ALE’s) must provide information to the IRS about health coverage offered to full time employees. What is an Applicable Large Employer (ALE)? An ALE generally means employers with 50 of more full-time employees (including full-time equivalent employees) in the preceding calendar year. I have less than 50 full-time employees (including full-time equivalent employees) in the preceding calendar year. Do I need to do anything? As long as you do not sponsor a self-insured group health plan you are not required to file under sections 6055 and 6056. I am considered an ALE and we offer our employees a plan under Blue Cross Blue Shield of Wyoming (BCBSWY). What tax forms will BCBSWY be providing to our employees and what will we need to provide? BCBSWY will be issuing a 1095-B to all participants who had coverage with BCBSWY annually. Additionally, you as a fully-insured employer, will be required to provide to each full-time employee a completed Form 1095-C (or a substitute form) . This form must be furnished FAQ (Frequently Asked Questions) regardless of whether the ALE offers coverage, or the employee enrolls in any coverage offered. An ALE is not required to furnish to its full-time employees a copy of Form 1094-C as filed with the IRS. What tax forms must an ALE fully-insured employer report to the IRS? The section 6056 regulations provide, under the general method of reporting, that an ALE must file a separate Form 1095-C (or a substitute form) for each of its full-time employees, and a transmittal on Form 1094-C (or a substitute form) for all of the returns filed for a given calendar year. These forms must be filed regardless of whether the ALE offers coverage, or the employee enrolls in any coverage offered. A more complete discussion of the information that must be reported to the IRS (including simplified methods of reporting) can be found in the final section 6056 regulations, in the final section 6055 regulations, and in the instructions to Form 1094-Cand Form 1095-C. The section 6056 required information also may be made by filing a substitute form, but the substitute form must include all of the information required on Form 1094-C and Form 1095-Cand satisfy all form and content requirements as specified by the IRS. Will BCBSWY collect TINs from individuals, including dependents, covered under its plan or policy? Yes. Reporting of TINs for all covered individuals is necessary for the IRS to verify an individual’s coverage. If BCBSWY is unable to obtain a TIN after making a reasonable effort to do so, the covered individual’s date of birth may be reported in lieu of a TIN. Will we, as an ALE, complete Part III of Form 1095-C? An ALE that offers coverage through an employer-sponsored insured health plan (and does not sponsor a self-insured health plan) should NOT complete Part III. Instead, information about coverage will be furnished to employees on Form 1095-B, which is filed by BCBSWY. FAQ (Frequently Asked Questions) Where can I find these forms? The links for the forms and ins

FAQs

What are IRS sections 6055 and 6056?

They are ACA reporting requirements under which applicable large employers must provide information to the IRS about health coverage offered to full-time employees.

Who is an Applicable Large Employer (ALE) and when is filing required?

An ALE generally has 50 or more full-time employees (including full-time equivalents) in the preceding calendar year. If you do not sponsor a self-insured group health plan, you are not required to file under sections 6055 and 6056.

What forms will a fully-insured employer and BCBSWY provide, and what determines whether Part III of Form 1095-C is completed?

BCBSWY issues a 1095-B annually to covered participants. A fully-insured ALE must provide each full-time employee a completed Form 1095-C (or a substitute form) regardless of whether coverage is offered or enrolled; an ALE offering through an employer-sponsored insured health plan should NOT complete Part III because coverage is furnished on Form 1095-B.

Sep 20, 2026

Upload by Ben