Form 1094-C

What is Form 1094-C?

Form 1094-C, titled “Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns,” is a form used by applicable large employers (ALEs) in the United States to transmit Forms 1095-C to the Internal Revenue Service (IRS). ALEs are employers with 50 or more full-time employees, including full-time equivalent employees, during the previous calendar year. Form 1095-C provides detailed information about the health insurance coverage offered to employees, while Form 1094-C is a summary transmittal form.

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Key Components

1. Employer Information:
   • The form begins with information about the ALE, including the employer’s name, address, Employer Identification Number (EIN), and contact information.
2. Certifications of Eligibility:
   • The ALE must provide information about its eligibility status and certification regarding the type of certification being made. This includes whether the employer is a member of a controlled group or an affiliated service group.
3. Monthly Qualifying Offer Method Transition Relief:
   • If applicable, the ALE can indicate if it is eligible for the transition relief for the Qualifying Offer Method for any month during the reporting year.
4. Section 4980H Full-Time Employee Count for ALE Members:
   • ALEs must report the total number of full-time and equivalent employees each month during the calendar year.
5. Section 4980H Transition Relief:
   • The form provides sections to report any transition relief claimed by the ALE regarding its employer shared responsibility under Section 4980H of the Internal Revenue Code.
6. Aggregate Certification:
   • The ALE certifies whether it offered minimum essential coverage to at least 98% of its total employees (and their dependents) during the reporting year.
7. Plan Start Month and Reference Month:
   • Indicate the start month of the health plan year and the reference month for determining the ALE’s status as an ALE.
8. Contact Person:
   • Provide information about the contact person responsible for answering questions about the information reported on Form 1094-C.
9. Authoritative Transmittal:
   • The ALE must designate whether the transmitted form is authoritative for the entire ALE group or only for the ALE member.
10. Signature:
    • The form requires the signature of an authorized individual along with their title, date, and telephone number.

How to Use

1. Complete Form 1095-C for Each Employee:
   • Before completing Form 1094-C, the ALE must first complete Form 1095-C for each full-time employee. Form 1095-C provides detailed information about the health insurance coverage offered to employees and whether they accepted or declined it.
2. Compile Aggregate Data:
   • Gather the necessary aggregate data for the reporting year, including the total number of full-time and equivalent employees, any transition relief claimed, and other relevant information.
3. Complete Form 1094-C:
   • Fill out Form 1094-C accurately, providing all required information, certifications, and aggregate counts for each month during the reporting year.
4. Verify Transition Relief Eligibility:
   • If the ALE is eligible for any transition relief, ensure that the appropriate sections of Form 1094-C are completed accurately, providing the necessary information and justifications.
5. Sign and Submit:
   • Sign and date Form 1094-C. If the ALE is part of a controlled group or affiliated service group, ensure that the form is signed by an authorized individual for the entire group.
6. Attach Form 1095-C:
   • Mail or electronically file Form 1094-C with the IRS, attaching the required copies of Form 1095-C for each full-time employee. The deadline for filing depends on whether the form is filed on paper or electronically.
7. Retain Records:
   • Keep copies of Form 1094-C and supporting documentation for at least three years. This documentation may be needed in case of an IRS audit.

Conclusion

Form 1094-C is crucial to the Affordable Care Act (ACA) reporting requirements for ALEs. It summarizes the health coverage offered to employees and helps the IRS monitor compliance with the employer-shared responsibility provisions under the ACA. ALEs should refer to the most recent IRS instructions for Form 1094-C for detailed guidance on completing the form and meeting reporting obligations.