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How to Complete and File Forms 1094-C and 1095-C for ACA Information-Reporting Purposes

Author: Gloria Ju

The Affordable Care Act (ACA) created two annual information-reporting requirements:

  • Under Section 6055 of the Internal Revenue Code (IRC), small self-insured employers, health insurance issuers, government agencies and other health coverage providers must report information on each individual to whom minimum essential coverage (MEC) was provided.
  • Under Section 6056 of the IRC, every applicable large employer (ALE) subject to the ACA's employer shared responsibility (or pay or play) mandate must report the terms and conditions of the health care coverage the employer offered to its full-time employees.

This information must be filed with the Internal Revenue Service (IRS) and furnished to individual employees. This How To will help an ALE correctly file and furnish Form 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns) and Form 1095-C (Employer-Provided Health Insurance Offer and Coverage Information Return) for Section 6055 and Section 6056 purposes. Note that substitute forms may be used, but the substitute forms must include all of the information required by Forms 1094-C and 1095-C and must satisfy all of the IRS's form and content requirements.

Forms 1094-B and 1095-B are to be used by a small self-insured employer that is not an ALE for Section 6055 purposes. See How to Complete and File Forms 1094-B and 1095-B for ACA Information-Reporting Purposes.