ACA Reporting Requirements – Forms 1095-C and 1094-C

ACA Reporting Requirements – Forms 1095-C and 1094-C

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by Jonathan Schulman on 07/22/2015Leave a Comment
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Employer Reporting Requirements:  1095-C and 1094-C

The 1094-C and 1095-C are filed by employers that are required to offer health insurance coverage to their employees under the Affordable Care Act.  The main difference between them is that the 1095-C provides information about health insurance to both employees and the IRS, while the 1094-C acts as a cover sheet about the 1095-C and is only sent to the IRS.

The role of the 1095-C

The ACA requires employers with at least 50 full-time workers to offer their employees health insurance.  And each year, those employers must send a statement – Form 1095-C – to all employees eligible for coverage.

The statement provides details about:

  • The cover offered to the employee
  • The lowest-cost premium available to the employee
  • And the months of the year when the coverage was available

All employees eligible for coverage should get a 1095-C, regardless of whether they actually participate in the employer’s health plan.

Where the 1094-C fits in:

Employers don’t send 1095-C forms just to their workers.  They also have to send them to the IRS.  When they do, they also file Form 1094-C.  This form is essentially a “cover sheet” for the 1095-C forms.  It provides information about:

  • The employer- including address, phone, EIN
  • How many employees it has
  • Name of the contact person
  • How many 1095-C forms are being sent


Why the IRS needs the 1095-C

The IRS needs information from 1095-C forms because it has a central role in enforcing the ACA.  Companies that are required to offer insurance but don’t, may have to pay a penalty.  By collecting 1095-C forms, the IRS can track who is and isn’t making coverage available to workers.

Filing information for employers

According to the IRS, employers must send employees their 1095-C forms by the end of January each year.  Information must be sent to the IRS by the end of February if paper filed, or by the end of March if the forms are filed electronically.  Make sure to discuss reporting with your health insurance broker or payroll service.

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