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Form 1094 Instructions Employers Need for the ACA Reporting Deadline

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The reporting deadline for Form 1094-C and 1095-C electronic filing is Thursday, June 30, 2016. Is your organization prepared? This article answers some frequently asked questions about ACA reporting forms and gives some helpful Form 1094-C instructions.

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When is the reporting deadline for employers to file Form 1094-C for the 2015 calendar year?

For reporting on the 2015 calendar year, employers must file Form 1094-C and 1095-C electronically by Thursday, June 30, 2016.

These dates are a result of the IRS extension given at the end of 2015.(The deadline for filing by paper for 2015 has already passed.)

In the future, filing for the previous calendar year will be due on February 28 (paper filing) and March 31 (electronic filing) unless the date falls on a weekend (Saturday or Sunday) or a legal holiday.

If a due date falls on one of the aforementioned days, the due date defers to the following business day. A business day, according to the IRS, is any day that is not a Saturday, Sunday, or legal holiday.

Penalties for failure to file complete and accurate forms by the form due date will be $250 per form, not to exceed $3 million.


Can I request an extension for the 1094 reporting deadline?

While traditionally ALEs would be able to request an extension by submitting Form 8809 on or before the due date of the return for an automatic extension, the IRS has declared the reporting deadline extension will serve as an automatic extension for all employers and no one may request an additional extension beyond June 30, 2016.

Who needs to file Form 1094-C for 2015?

Applicable Large Employers (ALE) with 50+ full-time and full-time equivalent employees in the previous year must file one or more Forms 1094-C and a Form 1095-C for each employee who was a full-time employee for any month of the calendar year.

It’s important to note that while many ALEs with fewer than 100 full-time equivalent employees are generally eligible for transition relief, they are still required to file Forms 1094-C and 1095-C for the calendar year 2015 and subject to penalties for failure to file forms.

Remember, no matter how your company qualifies full-time employees for its own purposes, the ACA’s standards apply to all employers.

What’s the purpose of Form 1094-C?

Under Code sections 6055 and 6056, ALEs must use Form 1094-C to report required information about whether or not the ALE offered affordable minimum essential health coverage (MEC) and enrollment in minimum essential health coverage for eligible employees. Form 1094-C will transmit forms 1095-C to the IRS.

Forms 1094-C and 1095-C will be used to determine whether an employer will be penalized for noncompliance. This penalty will require payment under the Employer Shared Responsibility provisions under section 4980H. These forms will also determine employees’ eligibility for the premium tax credit.


What determines if health coverage is affordable?

Health coverage is affordable if the amount charged by the employer for employee self-only coverage does not exceed 9.5% of the employee’s W-2 wages, pay, or the federal poverty level for 2015.


What information will be reported on Form 1094-C?

Employers will report the following on Form 1094-C for 2015:

  • The employer’s name, employer identification number, and contact information
  • The total number of Forms 1095-C filed (based on number of full-time equivalent employees during 2015 and any non-full-time equivalent employees who did enroll in the employer’s self-insured health plan.)
  • Proof by month as to whether the employer offered its full-time equivalent employees (and dependents) the opportunity to enroll in minimum essential health coverage
  • The number of full-time equivalent employees for each month of the calendar year 2015
  • The total number of employees for each month for the calendar year 2015
  • Any special rules or transition relief that applies to the employer
  • The names and employer identification numbers of other employers that are in a controlled group or affiliated service group with the employer


How to file Form 1094-C

The IRS strongly encourages a detailed review of instructions for 1094-C before completing the forms as well as a thorough evaluation of all forms before submission.

Instructions for 1094-C Electronic filing with the IRS

The IRS encourages all employers to file electronically if possible. However, if any employer must file 250 or more of a single type of form, the employer is required to file electronically. This requirement applies separately to each type of form. For example, if you’re filing 300 Forms 1094-C and only 100 of another form, you are required to file only the Forms 1094-C electronically. If an employer applies for and receives a hardship waiver, the electronic filing requirement is not applied.

You may file electronically through the AIR (ACA Information Returns Program)

Retain copies of all forms and returns filed with the IRS for at least three years from the due date. If you do not keep copies, you should be able to reconstruct the data given in the returns.


What are the next steps for employers?

Act now. These forms can be complicated, and unlike a W-2, can require information from multiple systems of record for one annual filing. Employers need to gather tracked information from Human Resources, payroll, benefits, etc. Waiting until the last minute to act on ACA tracking and reporting could leave your company facing big financial penalties and late fees. Start with the following action items:

Don’t let your organization get caught with big penalties. Prepare your business today for ACA compliance and reporting.

Download the Essential Guide to  ACA Compliance & Reporting