What filings does Vitable Support?
Vitable Provides data for the employer to file the following:
PCORI Fee
Creditable Coverage Disclosure
Gag Clause Prohibition Compliance Attestation
Form 5500
Vitable/TPA will submit the following for filing:
HCRA Reporting (when required)
RxDC
Section 111 Medicare
Form 1094-B & 1095-B
Form 1094-C & 1095-C
What filings is the employer responsible for submitting?
Vitable Provides data for the employer to file the following:
PCORI Fee
Creditable Coverage Disclosure
Gag Clause Prohibition Compliance Attestation
Form 5500
What does support look like for each filing?
For the filings the employer submits Vitable will provide the necessary data required for the employer to submit the filings with associated instructions. No additional support is provided by Vitable for these submissions.
For the filings that Vitable submits, Vitable will request data from the employer to move forward with the submissions. The data needs to be received by the requested date in order to ensure timely filing. Vitable is not responsible for any delays in filings due to or as a result of delayed delivery of the requested data by the employer.
When are each due to the IRS?
Filing | Filing Party | Filing Due |
PCORI Fee | Employer Submits | 7/31 |
Creditable Coverage Disclosure | Employer Submits | 10/15 |
Gag Clause Prohibition Compliance Attestation | Employer Submits | 12/31 |
Form 5500 | Employer Submits | 7/31 |
HCRA Reporting (when required) | Vitable/TPA Submits | 1/30 |
RxDC | Vitable/TPA Submits | 6/1 |
Section 111 Medicare | Vitable/TPA Submits |
|
Form 1094-B & 1095-B | Vitable/TPA Submits | 3/31 |
Form 1094-C & 1095-C | Vitable/TPA Submits | 3/31 |
What is required of the employer for Vitable to process these filings?
Vitable submits the following filings on behalf of the employer:
HCRA Reporting (when required)
No additional data required by employer
RxDC
No additional data required by employer
Section 111 Medicare
No additional data required by employer
Form 1094-B & 1095-B
Employer needs to provide all eligible employees for the plan year and social security numbers by [2027 date TBD] if it was not already available to Vitable through HRIS integration. You will receive an email from vitable requesting the information in late December.
Form 1094-C & 1095-C
Employer needs to provide all eligible employees for the plan year and social security numbers by [2027 date TBD] if it was not already available to Vitable through HRIS integration. You will receive an email from vitable requesting the information in the coming months.
When will Vitable request data from the employer for filing?
Form 1094-B & 1095-B: Employers will be required to provide Vitable with a full list of eligible employees and social security numbers, addresses, DOB and contact information if we do not have it. Dependent information should also be included where applicable. This information must be provided to Vitable no later than [2027 date TBD]. The request for the data will be submitted to employers no later than the [2027 date TBD].
Form 1094-C & 1095-C: Employers will be required to provide Vitable with a full list of eligible employees and social security numbers, addresses, DOB and contact information if we do not have it. Dependent information should also be included where applicable. This information must be provided to Vitable no later than the [2027 date TBD]. The request for the data will be submitted to employers no later than [2027 date TBD].
Why are employers required to complete these requirements?
Self-funded plans (where the employer is responsible for paying the claims of the plan) are subject to a number of regulations and reporting requirements. Based on the plan type, geography and size of the company, certain reports must be filed.
What are these filing requirements?
Filing Name | Short Description |
Form 5500 | Filing for the Department of Labor on all wage and benefit plans offered to employees at employers that have more than 100 employees. |
PCORI | Self-funded plans pay a small excise tax towards government research. PCORI is paid through a filing of Form 720 to the IRS. |
1094/1095 | Employer and employee reporting to the IRS that satisfies ACA regulations. |
HCRA | Specific state based reporting for self-funded and fully insured plans on payments to certain vendors. |
Gag Clause Prohibition | Annual filing for self-funded plans around the transparency of claims level data available to employers. |
RxDC | Annual filing with Center for Medicare Services (CMS) that focuses on prescription drug utilization of health plans. |
Section 111 Medicare | Annual filing with CMS on treatment of members eligible for Medicare. |
Can Vitable file my forms if I wasn’t a Vitable client for the full year?
Vitable will assist with and complete reporting for the period of time that clients were provided a health plan by Vitable. For periods of the year when you were not a Vitable client, please contact your previous TPA or service provider to confirm that they have filed for that period on your behalf.
Can Vitable change the date I began offering plan benefits?
No, Vitable will not adjust or alter any information regarding your plan benefits this includes but is not limited to the date benefits began or ended, eligibility, enrollment, or employees offered benefits.
Can Vitable add employees to the eligible employees list if I forgot to include them or offer them benefits?
No, Vitable will not adjust or alter any information regarding your plan benefits this includes but is not limited to the date benefits began or ended, eligibility, enrollment, or employees offered benefits.
1094/1095 Filing for 2025 Plan Year
When will I receive a request for my employee's SSN numbers and why are these required?
SSNs for eligible employees are required to be provided by employers in order for Vitable to generate and file your 1094/1095c forms. Emails will go out to you requesting SSN numbers for employees. The dates for filings conducted in 2027 have yet to be determined, but will be updated soon.
Who is responsible for filing 1094/1095 forms?
Vitable will file these on the employer's behalf
Will I receive a copy of my 1094/1095c forms?
Yes, a copy will be provided in the same secure inbox you submit your SSNs to.
What is the process and timeline for filing this year?
You will receive an email by [2027 date TBD]with a link to a file of your eligible employees. You must provide their SSNs by [2027 date TBD] in order to allow Vitable enough time to process and submit these for filing.
Vitable will generate your 1094/1095 forms and file them with the IRS
Vitable will provide a copy of your 1094/1095 C forms in the same secure location that houses your employee SSNs.
What is the filing deadline for 1094/1095 forms?
Forms must be filed by March 31, 2026
For any questions please contact compliance@vitablehealth.com