As the deadlines for ACA reporting approach, we want to ensure you're well-prepared to meet your reporting responsibilities. The reporting landscape can be complex, but rest assured, you're not alone on this journey. Let's break down what you need to know and do to stay compliant.
Understanding ACA Reporting Requirements
By now, you should have received an email or correspondence from your carrier with a link to their portal. This is where you will input the necessary information for the insurance company to report your plan details to the IRS. It's crucial to keep an eye out for this communication and act promptly, as the first deadline is fast approaching on February 28, 2026.
Here's a quick recap of what's required:
Small Employers (Fully Insured): You are exempt from 1094/1095 filing. Your insurance carrier generally takes care of this on your behalf.
Small Employers (Level or Self-Funded, Not an ALE): You must file the 1094-B and 1095-B forms. Although carriers might assist, the filing responsibility ultimately lies with you.
Applicable Large Employers (ALEs): Regardless of being fully insured or level/self-funded, you must complete and file the 1094-C and 1095-C forms.
Many payroll companies offer assistance with these filings, but you may need to provide them with your current plan information to ensure accuracy. Additionally, many carriers offer free portal services for filing, so check your emails for opportunities to utilize these resources.
Rx DC Filing: Continuing Compliance
While the Rx DC (Prescription Drug Data Collection) report isn't a new requirement, it's an ongoing compliance aspect under the Consolidated Appropriations Act (CAA), 2021. This annual filing mandates employers and health insurers to submit data on prescription drug costs and healthcare spending to the Centers for Medicare & Medicaid Services (CMS). The data for the 2025 reference year is due by June 1, 2026.
Key Aspects of Rx DC Filing:
- Who Must File: Group health plans (insured and self-funded) and insurance issuers.
- What is Reported: Data includes premium information, total healthcare spending (categorized by hospital, primary, and specialty care), and prescription drug rebates.
- Submission Method: Data is submitted via the Health Insurance Oversight System (HIOS).
- Structure: The report consists of a plan list (P2 file) and several data files (D1-D8), often accompanied by a narrative response.
Action Steps for Employers:
- Verify Vendor Support: Most employers rely on third-party administrators (TPAs) or Pharmacy Benefit Managers (PBMs) to submit this data. Follow the steps outlined by your carrier in the communication they have sent you.
- Confirm Responsibility: Ensure a written agreement is in place with your vendor to submit on your behalf. However, remember that for self-insured plans, the employer retains ultimate liability.
- Submit by Deadline: The annual deadline remains June 1 for the preceding calendar year's data.
Failure to comply with RxDC reporting requirements can result in penalties, as it's a crucial part of CAA compliance. Your carrier has likely sent you a link to file this information. If you haven't seen it yet, expect a reminder soon. The form typically takes about five minutes to complete online through the carrier’s website.
Frequently Asked Questions (FAQs)
Q: What happens if I miss the ACA reporting deadline? A: Missing the deadline can result in penalties. It's essential to adhere to the deadlines provided to avoid any compliance issues.
Q: Can payroll companies handle all my reporting needs? A: Many payroll companies can assist with ACA filings, but it's important to confirm with your provider and ensure they have your current plan information for accuracy.
Q: Is RxDC filing mandatory for all employers? A: Yes, RxDC filing is mandatory for group health plans and insurance issuers, regardless of the size of the employer.
Q: How can I ensure my data is submitted correctly for RxDC reporting? A: Verify that your third-party administrators or Pharmacy Benefit Managers are submitting on your behalf and have a written agreement to that effect.
Q: What support is available if I have questions about my reporting responsibilities? A: We're here to help! Please reach out if you need assistance or have any questions about your reporting obligations.
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We’re Here to Help
As always, we're here to provide the information you need. If you have any questions or require assistance, please don’t hesitate to reach out. We’re committed to supporting you and ensuring you feel confident and prepared to meet these requirements effortlessly.