Understanding ACA Reporting Requirements
All Sana groups are required to complete ACA reporting because Sana plans are self-funded.
What’s Changing for 2026?
For 2026 ACA reporting, Sana will provide your group’s raw ACA data at no cost, but Sana will no longer coordinate the preparation, distribution, or filing of ACA forms.
Your group is responsible for:
- Preparing the appropriate Forms 1094 and 1095
- Distributing required forms to employees
- Filing required forms with the IRS and any applicable state or jurisdiction
You can complete ACA reporting yourself or work with a third party. If you need help identifying a filing solution, we recommend working with your broker.
What is ACA Reporting?
ACA reporting is how employers share information with the IRS about the health coverage they offer to employees.
It helps the IRS enforce two main ACA rules:
- Employer Mandate: Certain employers must offer health coverage to full-time employees.
- Individual Mandate: Individuals are generally required to have health coverage (note: there’s no federal penalty today, though some states still enforce this.)
Who Needs to Report?
ACA reporting requirements vary based on employer size:
Applicable Large Employers (ALEs)
Who this is: Employers with 50 or more full-time employees (including full-time equivalents) in the previous calendar year.
What’s required:
- File IRS Forms 1094-C and 1095-C
Why:
- To show that eligible employees were offered minimum essential coverage
Small Employers (Fewer than 50 FTEs)
Most small employers do not need to complete ACA reporting.
Exception: If you offer self-funded coverage (including Sana’s level-funded plans), ACA reporting is required.
What’s required:
- File Form 1095-B (plus a 1094-B transmittal)
- Covers all individuals enrolled in the self-funded plan
All Sana plans are self-funded. This means every Sana group must complete ACA reporting, regardless of whether the group is considered an ALE.
State Reporting Requirements
Some states and jurisdictions have additional ACA-related reporting requirements.
Groups with primary enrollees in California, Massachusetts, New Jersey, or Rhode Island must also complete applicable state reporting. Groups covering residents of Washington, D.C. must also report to D.C.
How to Meet ACA Reporting Requirements
If you're a Sana Admin using a level-funded plan, your company is technically self-funded. Groups are responsible for preparing, distributing, and filing their required ACA forms.
Groups have two options
Self-file: Sana provides raw data at no cost, and the group prepares, distributes, and files Forms 1094/1095 with the IRS.
Use a third party: Work with an outside service, such as your payroll provider, accounting firm, or an ACA vendor.
E-filing may be required depending on how many forms are filed (e-file requirements), and groups e-filing directly should review IRS AIR.
Key ACA Reporting Deadlines
For the most up-to-date deadlines, refer directly to IRS guidance.
FAQ
What’s the difference between 1095-B and 1095-C?
- 1095-B: Used by insurance carriers or small self-funded employers.
- 1095-C: Used by ALEs to report coverage they offered to employees.
How do I know if I’m an ALE?
- For Tax Year 2026, groups that averaged 50 or more full-time employees and full-time equivalent employees during 2025 are considered Applicable Large Employers (ALEs).
- ALEs must complete the applicable 1095-C and 1094-C reporting requirements.
Can brokers help with ACA reporting?
Absolutely. Brokers can support their clients by helping determine ALE status, answering general compliance questions, and helping groups choose a filing partner or ACA reporting vendor.
Do employees need their ACA forms to file taxes?
Not usually. These forms are informational. Employees can file their taxes without them but should keep them for their records.
Why is Sana no longer coordinating ACA filings?
Most Sana groups already manage their ACA reporting independently. Sana will continue supporting groups by providing the raw data needed to complete their reporting at no additional cost.
Groups can use this data to file independently or work with the third-party filing partner of their choice.
Need Help?
For questions about your company’s ACA reporting responsibilities or how Sana supports your group, reach out to your Sana Customer Success Manager.