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      IRS ACA: Correcting Forms 1094-C for Resubmission

      How to properly correct forms 1094-C to be resubmitted to the IRS. This may need to be done to address IRS errors in response to your original filing or to amend a form(s) for any issue you have identified.

       

      A new form 1094-C needs to be created when submitting either Correction or Replacement files to address any errors received from the IRS in response to the original ACA submission for your company.  Each situation calls for different handling of the new form 1094-C.


      Scenarios
      1. If your original ACA submission received a response from the IRS of "Accepted with Errors,"  AND there were only Form 1095-C errors, you need to create a non-Authoritative Form 1094-C.  This Form 1094-C should NOT be marked as "CORRECTED," as only the Forms 1095-C that had errors will be marked as "CORRECTED" in this scenario.
        1. Your resubmission to the IRS will contain both your "CORRECTED" Forms 1095-C AND this new Form 1094-C.
        2. On line 18 of your new form 1094-C, enter the # of Corrected Forms 1095-C that are being submitted to the IRS
      2. If your original ACA submission received a response from the IRS of "Accepted with Errors," AND there were only Form 1094-C errors, you need to create a new Authoritative Transmittal Form 1094-C.  This Form 1094-C must have an "X" in the "CORRECTED" in this scenario.
        1. Your resubmission to the IRS will contain only the standalone "CORRECTED" Form 1094-C.
      3. If your original ACA submission received a response from the IRS of "Accepted with Errors," AND there were errors for both Forms 1095-C and Form 1094-C, you need to create 2 new Forms 1094-C in this scenario. 
        1. The first will be a non-Authoritative Form 1094-C, NOT marked as "CORRECTED," to be included with the resubmission of your "CORRECTED" Forms 1095-C.
          1. On line 18 of your new form 1094-C, enter the # of Corrected Forms 1095-C that are being submitted to the IRS
        1. The second will be a new Authoritative Transmittal Form 1094-C, marked as "CORRECTED," to be resubmitted as a standalone form.
      2. If your original ACA submission received a response from the IRS of "Rejected," AND there were 1094-C errors, you need to create a new Authoritative Transmittal Form 1094-C, NOT marked as "CORRECTED." 
        1. Your resubmission to the IRS will contain both your updated Forms 1095-C AND this new Form 1094-C without any forms being marked as "CORRECTED."
      3. If your original ACA submission received a response from the IRS of "Rejected," AND there were only Form 1095-C errors, you do NOT need to create a new Form 1094-C, as the original form can be used in this scenario.
        1. Your resubmission to the IRS will contain both your updated Forms 1095-C AND your original Form 1094-C without any forms being marked as "CORRECTED."

       

      To create your new Form 1094-C to be included in either your Correction or Replacement file submissions to the IRS, you must complete the following steps.

      • Update Incorrect Data in your Company settings, i.e., ACA Settings widget, ALE Group List, Benefit Plans, etc.
      • Create, Populate, and Finalize new Form(s) 1094-C, per the scenarios above