How to File Forms 1094-C and 1095-C for ACA Compliance– September 24, 2015

The IRS has developed new forms for the ACA’s information reporting requirements. Due February 29, 2016, if paper filed and March 31, 2016 if e-filed, Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage will require gathering multiple points of information from various departments in your company. This compliance is not an effort to be undertaken lightly. Below is the information you will need to get through them, preferably in conjunction with your tax advisors to help ensure full compliance.

Form 1094-C

To complete this form, you will need:

  • Identifying information for your organization,
  • Information about whether you offered coverage to at least 70% of your full-time employees and their dependents in 2015 (after 2015, the threshold rises to 95%), and
  • For the Authoritative Transmittal:
    • Total number of Forms 1095-C you issued to employees,
    • Information about members of the aggregated ALE group (if any),
    • Full-time employee counts by month,
    • Total employee counts by month, and
    • Whether you’re eligible for certain transitional relief.

If an employer is a controlled group, it can file a separate Form 1094-C for each member, with each member’s full-time employees. However, one of the forms must be designated as the “Authoritative Transmittal” reporting aggregate employer-level data for all of the members.

Form 1095-C

To complete this form, you will need to know:

  • Who is a full-time employee for each month,
  • Identifying information for employer and employee,
  • Information about the health coverage offered by month (if any),
  • The employee’s share of the monthly premium for the lowest-cost, self-only minimum value coverage,
  • The months the employee was enrolled in your coverage,
  • The months an affordability safe harbor applies for an employee and whether other relief applies for an employee for a month, and
  • If you offer a self-insured plan, information (including Social Security number or, if the Social Security number isn’t available, date of birth) about the covered individuals enrolled in the plan (including spouses and dependents), by month.

You can satisfy the employee statement requirement by providing employees a copy of Form 1095-C. A substitute form may be used instead, as long as the form includes all of the required information and complies with the relevant IRS guidance. A non-ALE self-insured employer should file Forms 1094-B and 1095-B.

Electronic Filing
Both forms are subject to requirements related to electronic filing. Employers that will file 250 or more information returns must file electronically through the ACA Information Returns (AIR) system. This requirement applies separately to each type of return and separately to each type of corrected return.

IRS Publication 5165, Guide for Electronically Filing Affordable Care Act (ACA) Information Returns for Software Developers and Transmitters, provides detailed technical information for returns transmitted through the AIR system. Publication 5164, Test Package for Electronic Filers of Affordable Care Act (ACA) Information Returns (AIR), contains general and program-specific information on the testing that must be passed prior to using the system.

We urge employers to contact their tax advisors as soon as possible to confirm they are on track for compliance, or to devise a plan to begin information gathering to meet the deadlines. Read more about the reporting requirements in general in our blog: ACA Reporting Deadlines on the Horizon: Are You Ready?

Contact Maura Corrigan at to discuss your ACA tax compliance obligations further.

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