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FAQ in HR | Sep 05, 2019

ACA Question: Does Your Small Group Have to File ACA Forms?

ACA Question: Does Your Small Group Have to File ACA Forms?

Filing ACA is different for some small groups. 

While most Applicable Large Employers understand they must file 1094 & 1095 forms, small groups (those under 50 employees) are often confused as to their reporting requirements under the Affordable Care Act. 

Whether a small group has to file 1094 & 1095 forms depends upon the type of insurance they offer – fully-insured or self-insured.

• Fully-insured plans are the more traditional offerings. The employer pays fixed rate premiums to a carrier based upon the number of employees enrolled in the plan each month.

• Self-insured plans are plans operated and funded by the employer. Self-insured plans also include “level funded” plans which are becoming more popular with small groups.

The reporting requirements are as follows:


It is important that small groups understand 1) the type of insurance they offer and 2) if they offer self-insured plans (including level funded plans) they must file the required 1094B & 1095B forms. Failure to file the forms can lead to significant penalties and fines.

If you have any questions regarding this topic or others related to HR feel free to reach out to Chris Cooley at 855-538-6947 ext 108.

The HR and business professionals at MyHRConcierge are here to respond to your questions and concerns, and keep small to medium-sized businesses compliant with federal and state labor laws. Delivering personal service to our Partners and Clients is the heart and soul of our business.