Employers with 50 or more full-time employees (including full-time equivalents) in the prior year must use Forms 1094-C and 1095-C to comply with IRS reporting requirements under Internal Revenue Code sections 6055 and 6056. These forms provide information on health coverage offerings and employee enrollment.
Purpose of Forms 1094-C and 1095-C
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- Form 1094-C: Serves as a summary document for each applicable large employer (ALE) member and is used to transmit Forms 1095-C to the IRS.
- Form 1095-C: Reports details about each full-time employee’s health coverage to both the IRS and the employee. It also helps determine if an ALE member owes an employer shared responsibility payment under section 4980H and whether an employee qualifies for premium tax credits.
- ALE Members providing self-insured health plans also use Form 1095-C to report minimum essential coverage details to the IRS and employees.
Who Must File?
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- Applicable large employers (ALEs): Entities with at least 50 full-time employees (including equivalents) in the prior year.
- Aggregated ALE groups: If multiple employers are under common control and collectively meet the 50-employee threshold, each entity within the group is an ALE member and must file separately.
- Filing requirements: ALE members must submit at least one Form 1094-C (including an Authoritative Transmittal, if filing multiple forms) and a Form 1095-C for each full-time employee.
- Employers must also provide employees with a copy of their Form 1095-C.
Filing Deadlines
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- Paper Filing: February 28 of the year following the reporting year.
- Electronic Filing: March 31 of the year following the reporting year.
- If the due date falls on a weekend or legal holiday, it moves to the next business day.