The Affordable Care Act (ACA) requires most individuals to obtain minimum essential health coverage or pay a penalty, with some exceptions. The penalty for not having coverage is to be paid when individuals file their federal tax return; for the 2015 tax year, the filing deadline is April 15, 2016. The recently postponed ACA reporting deadlines for employers may leave some wondering—What do employees need to do to prove they have minimum essential health coverage? Do employees need to wait for their 1095-B and 1095-C forms before they can file their tax returns?

1-14_aca-reporting-deadline-delay-tax-filing-delay with dash
Starting for calendar year 2015, employees are to receive a form from their insurer or employer indicating coverage (IRS Form 1095-B or 1095-C). Originally, the forms were required to arrive by the Form W-2 deadline (normally January 31, but February 1 for 2016). In late December, however, the IRS extended the reporting deadline for insurers and employers to March 31, 2016. (The delay is in place only for 2015 because it is the first year of reporting. For 2016 and beyond, the deadline will match the W-2 deadline.) While some insurers and employers may send employees the forms in advance of that extended deadline this year, others will take advantage of the extra time.

[Final Preparation for Filing the 1094/1095—Watch on demand for step-by-step guidance.]

Does this mean employees have to wait to file their tax returns?

No. The IRS has clarified that individuals do not have to delay filing their income tax returns because they have not yet received Form 1095-B or 1095-C. For the 2015 tax year, they can rely on the types of documentation listed below as proof of coverage. They can file their income tax returns before they receive Form 1095-B or 1095-C. (As an aside, none of the documents listed below must be sent to the IRS as attachments.) Also, individuals don’t have to file an amended return once they receive one of the forms from their insurer or employer. If individuals file their income tax return AFTER receiving Form 1095-B or 1095-C, for 2015 they don’t have to include the form with the return; it should be kept with their records.

How can individuals prove they have coverage when they file their tax return? The government suggests these forms of documentation as proof of insurance coverage:

  • Insurance cards
  • Explanation of benefits
  • Statement(s) from insurers
  • W-2 or payroll statement(s) reflecting health insurance deductions
  • Record(s) of advance payments of the premium tax credit, and
  • Other statements indicating an individual or family member had coverage.

Tax-filing procrastinators won’t catch a lucky break this time. The April 15 filing deadline lives on.

Stay tuned to ACA University and ACA Central for more updates as they happen!

Julie Stich, CEBS
Director, Research at the International Foundation

Julie Stich, CEBS

Director, Research at the International Foundation Favorite Foundation service/product: A tie between our research reports and the personalized research service! Benefits related topics she’ll happily discuss: Issues involving women in retirement, ACA, innovative benefits, trends, communicating the value of benefits, work/life benefits and “fuzzy” benefits.

Favorite Foundation conference/event moment: Listening to astronaut Col. Chris Hadfield’s keynote at the 2014 Canadian Annual Conference. Also, really likes being in a booth at whichever conference, and chatting with members.

Personal Insight: A history buff, Julie enjoys traveling to major U.S. landmarks. She is also a life-long Trekker, and will correct you if you mistakenly call her a “Trekkie.”  

Recommended Posts

Legal & Legislative Reporter: Medical Provider May Not Bring Claim on Behalf of Participants and Beneficiaries

Guest Contributor

Every month, the International Foundation releases the Legal and Legislative Reporter, a compilation of new employee benefits–related case summaries. Below is a summary we thought you’d be interested in. Content provided by Morgan, Lewis & Bockius LLP. The U.S. District Court for the […]

Five Steps to Nurture Belonging in the Workplace

Guest Contributor

Benefits Magazine Extras articles provide you with bonus content on a mix of benefits topics as well as deep dives and analyses on the latest benefit trends and compliance issues. Visit to see the latest Benefits Magazine Extras as well as the bimonthly print […]

Navigating Uncertainty

Christine Vazquez, CEBS

In today’s business environment, change is constant. Earning a Certified Employee Benefit Specialist® (CEBS®) designation can help benefits professionals improve their ability to manage organizational change. The self-study CEBS courses provide critical knowledge and skills to scan the environment and strategically tailor benefit […]

DOL Guidance on Mental Health Parity: Proposed Rules for NQTL Comparative Analyses

Jenny Gartman, CEBS

Many health plan sponsors continue to struggle to comply with the Mental Health Parity and Addiction Equity Act (MHPAEA), particularly the requirement to conduct a comparative analysis of nonquantitative treatment limitations (NQTLs) that has been effective under the 2021 Consolidated Appropriations Act […]