Preparing Employers for 2016 ACA Information Reporting: Lessons From 2015 Compliance Missteps

Navigating New and Expanded 2016 Reporting Requirements and Revised Forms 1094-C and 1095-C; Avoiding IRS Audits and Penalties

Recording of a 90-minute premium CLE/CPE webinar with Q&A

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Conducted on Tuesday, October 25, 2016

Recorded event now available

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Course Materials

This CLE/CPE course will provide guidance to employee benefits counsel on preparing employers for 2016 Affordable Care Act (ACA) information reporting, which must be filed in early 2017. Using lessons from 2015 reporting as a roadmap for the discussion, the panel will discuss the anticipated elimination of deadline extensions and transition relief, the changes to Forms 1094-C and 1095-C, and effective planning and compliance techniques to avoid IRS audits and penalties.


The complexity of the ACA information reporting provisions presented several challenges for employers during 2015 reporting, including discovering that their health plans were out of compliance with the ACA in some areas; failing to anticipate the cumbersome and complex nature of the reporting forms, which resulted in missed filing deadlines; and relying on inaccurate reporting advice from third parties. Understanding the problems and pitfalls employers faced last year and the lessons therefrom is key to helping clients avoid missteps when planning for 2016 information reporting.

Benefits counsel must also understand and advise employers of the new changes to the requirements for 2016 reporting, which represent a long-awaited expansion of the duties for mid-size and larger employers. Key to the new regime is that the standard for assessing penalties has become much stricter—there is no longer a “good faith effort” exception. Changes have also been made to Forms 1094-C and 1095-C.

Additionally, smaller employers are facing additional filing challenges, as reporting requirements expand and the phased implementation of the ACA continues. Further, employers must begin planning for the 40% surtax on “Cadillac” plans.

Listen as our authoritative panel reviews lessons and pitfalls from 2015 ACA information reporting and how to avoid similar problems with 2016 reporting. The panel will also discuss new changes that will impact 2016 reporting. The panel will offer planning techniques for both applicable large employers as well as small employers who are not subject to the employer mandate but may still have reporting obligations, and will outline the steps employers should take now to bring their plans into compliance with the ACA and avoid penalties.



  1. Problems and pitfalls employers faced during 2015 ACA reporting and lessons learned
  2. New changes for 2016 ACA reporting
    1. Forms
    2. Deadlines
    3. Penalties
    4. Surtax on “Cadillac” plans
  3. Best practices for planning and compliance


The panel will review these and other key issues:

  • What challenges did employers face during 2015 ACA information reporting and how can those problems be avoided for 2016 reporting?
  • What are the key changes to the requirements and forms for 2016 reporting?
  • What are some best practices for employers for planning for 2016 reporting and ensuring their plans are in compliance with the ACA?


Amin, Kathryn
Kathryn Amin

Groom Law Group

Ms. Amin helps employers, self-funded plans and insurers understand their obligations under the ACA, including the...  |  Read More

Joanna C. Kerpen
Joanna C. Kerpen

McDermott Will & Emery

Mrs. Kerpen focuses her practice on a variety of employee benefits tax and ERISA matters related to 401(k) plans,...  |  Read More

Malcolm C. Slee
Malcolm C. Slee

Of Counsel
Groom Law Group

Mr. Slee advises employers, issuers, plan administrators, associations, and plan trustees on a comprehensive range of...  |  Read More

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