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ACA 1094-C and 1095-C Reporting Requirements

Issued: Nov. 20, 2015
Updated: Dec. 09, 2019 – View Changes

FPP F.039


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ERS Reporting

For questions about Form 1094-B and 1095-B:

Comptroller Reporting

For questions about Form 1094-C and 1095-C:


Applicable to

State agencies using the:

  • Uniform Statewide Payroll/Personnel System (USPS)
  • Centralized Accounting and Payroll/Personnel System (CAPPS) HR/Payroll — Central agencies only

Note: See Employer Reporting for the reporting requirements for the Texas Department of Transportation (TxDOT), Texas Department of Criminal Justice (TDCJ), Health and Human Services (HHS) agencies, Cancer Prevention and Research Institute of Texas (CPRIT) and Texas Workforce Commission (TWC).


The Patient Protection and Affordable Care Act of 2010 (ACA) requires employers to offer affordable health insurance that provides minimum essential coverage to their full-time (and full-time equivalent) employees and their dependents or incur tax penalties.

The ACA also creates reporting requirements for employers and health care providers:

  • Forms 1094-B and 1095-B: Internal Revenue Code (IRC) Section 6055 requires health plans to report enrollment information to the Internal Revenue Service (IRS) and give a related statement to the responsible individual (typically the employee).
  • Forms 1094-C and 1095-C: IRC Section 6056 requires applicable large employers to file information returns with the IRS and give statements to employees about the health insurance coverage offered by the employer.

Note: Your agency is responsible for 1094-C and 1095-C reporting. This means that your state agency is responsible for reporting the Offer of Coverage Information (Parts I and II of Form 1095-C) for all employees.

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Health Plan Reporting

Delegation to ERS

On Oct. 5, 2015, the Employees Retirement System (ERS) notified all agencies of the process required to delegate the authority to file and furnish Forms 1094-B and 1095-B to ERS.

HealthSelect Enrollment Information

Your agency completed the required delegation to ERS, and enrollment information required in Part III of Form 1095-C for participants in HealthSelect of Texas will be delegated to ERS to be reported on Forms 1094-B and 1095-B for tax year 2019.

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Employer Reporting

USPS and CAPPS HR/Payroll Agencies

Since USPS and CAPPS HR/Payroll agencies provide the data for Form 1095-C (Parts I and II) to the Comptroller’s office, those agencies may designate the Texas Comptroller of Public Accounts for the reporting of Form 1095-C (Parts I and II).

  • Agencies delegated Parts I and II to the Comptroller’s office and also delegated Part III to ERS.
  • In December 2015 agencies designated the Comptroller’s office as the government entity for Forms 1094-C and 1095-C on the Designation of Government Entity for ACA Reporting form, and that designation remains in effect unless terminated under the terms of the agreement.
  • Based on that designation, the Comptroller’s office will also complete the required 1094-C reporting to the IRS on the agency’s behalf.

TxDOT, TDCJ, HHS Agencies, CPRIT and TWC

TxDOT, TDCJ, HHS agencies, CPRIT and TWC will be required to complete Forms 1094-C and 1095-C for their employees and the IRS.

For those agencies, only Part I and Part II will be reported for the 1095-C because ERS will report the Part III information on the Forms 1094-B and 1095-B, based on the ERS delegation form.

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IRS Reporting Deadlines

  • Forms 1095-B and 1095-C must be distributed to responsible individuals on or before March 2, 2020.
  • Information from Forms 1094-B and 1094-C must be submitted to the IRS on or before March 31, 2020, if filing electronically.

State Agency Timeline

IRS Deadlines Type of Agency Timeline
March 2, 2020 –
Deadline for Distribution of Forms 1095-B and 1095-C to Responsible Individuals

March 31, 2020 –
Deadline for Submission of Information from Forms 1094-B and 1094-C to the IRS, if filing electronically.
USPS and CAPPS HR/Payroll Agencies (Central Agencies Only)
  • The Comptroller’s office plans to have the forms to agencies for distribution to employees on or before Feb. 21, 2020.

    The forms may not be available at the same time the W2s are ready for distribution.

  • The Comptroller’s office plans to submit the form information to the IRS on or before March 31, 2020.
TxDOT, TDCJ, HHS agencies, CPRIT and TWC
  • You are responsible for setting your own timeline for distribution of the forms to your employees and submitting the form information to the IRS.

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Changes to this Document
Date Updates
12/09/2019 Updated for 2020 reporting for tax year 2019
12/04/2018 Updated for 2019 reporting for tax year 2018
11/30/2017 Updated for 2018 reporting for tax year 2017
12/01/2016 Added Health and Human Services (HHS) agencies, Cancer Research Institute of Texas (CPRIT); updated deadlines and added web form
01/19/2016 Added IRS Extension of Reporting Deadlines