IRS ACA Error: 1094-C Part III Column (a) is Missing Values

How to address the "1094-C Part III Column (a)" error from the IRS in response to your ACA data submission. (Error Codes 1094C-038-03 or 1094C-041-02)

Form 1094-C, Part III, Column (a), "Minimum Essential Coverage Offer Code," is missing values.


  • Identify the cause of the error.
    • Under Part III, Column (a) "Minimum Essential Coverage Offer Indicator," if not every month (rows 24 - 35) have either a "Yes" or "No" box selected, then "All 12 Months" (row 23) must have either a "Yes" or "No" selected, and vice versa.
  • Correct the error in Fuse.
    • Creating new Form(s) 1094-C for Resubmission
    • Instead of manually checking the boxes under Column (a), use the "Populate Form" button to complete the "1094 Questionnaire Confirmation" pop-up window and ensure your new form 1094-C is completed correctly.
    • If you have selected the option "A Minimum Essential Coverage (MEC) plan was offered to at least 95% (70% in 2015) of full time employees and dependents" you will see additional options appear below, allowing you to either select "All Months" or each of the individual months that should have the "Yes" box selected on your form.