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.

Step 1: Determine Whether the Employer Must Report

An ALE that has an insured major medical plan must report information about offers of group health coverage and enrollment in health coverage for its full-time employees; an ALE that is self-insured must report information about offers of group health coverage to any employee who enrolls in that coverage. An ALE that did not have a full-time employee in any month of the year is not required to report under Section 6056. Those that sponsor a self-insured plan must report information about individuals who have MEC under the employer plan, even if it has no full-time employees.

Step 2: Obtain an Employer Identification Number, If Needed

Forms 1094-C and 1095-C both require an Employer Identification Number (EIN). An employer that does not have an EIN may apply for one by:

  • Going to IRS.gov; or
  • Faxing or mailing Form SS-4, Application for Employer Identification Number, to the IRS.

Step 3: Fill Out Form 1094-C (Transmittal Form)

An employer must file a Form 1094-C when it files one or more Forms 1095-C. See Step 4: Fill Out Form 1095-C (Information Return).

Part I - Applicable Large Employer Member

Lines 1-8: Require completion of the ALE's name and address (including room or suite number, if applicable), the EIN, and the name and telephone number of the person to contact with questions. The employer address used here should match the one used on Form 1095-C.

NOTE: Only a Designated Governmental Entity (DGE) filing on behalf of an employer should complete Lines 9-16. A DGE is a person that is part of or related to the governmental unit that is the ALE member and that is appropriately designated for purposes of these reporting requirements. If the preparer is not a DGE, skip to Line 18. A DGE that is filing Form 1094-C is required to have a valid EIN. A DGE that does not have an EIN may apply for one by following the instructions in Step 2.

Lines 9-16: Require completion of the DGE's name and address (including room or suite number, if applicable), the EIN, and the name and telephone number of the person to contact with questions.

Line 17: Is reserved for future use.

Line 18: This line is used to enter the total number of Forms 1095-C that are being transmitted with the Form 1094-C.

Line 19: An employer filing multiple Forms 1094-C (in instances where transmittals are filed in multiple batches so that not all Forms 1095-C are attached to a single Form 1094-C) must designate one of the Forms 1094-C as the Authoritative Transmittal, which reports aggregate employer-level data for the employer. An ALE that is a member of a controlled group and that is required to report must file separate Forms 1094-C.

If the Form 1094-C is not the Authoritative Transmittal, then the employer must complete the signature portion, but should not complete Part II, Lines 20-22, and all of Parts III and IV.

Part II - ALE Member Information

Lines 20-22 should be completed only on the Authoritative Transmittal.

Line 20: The total number includes all Forms 1095-C that are filed for any individuals who enrolled in the employer-sponsored self-insured plan and that are filed with a separate transmittal filed by or on behalf of the employer.

Line 21: An employer should check "yes" if it was a member of an aggregated ALE group during any month of the calendar year. Such employers should complete Part III, Column (d), and Part IV. If the employer was not a member of a controlled group for all 12 months of the calendar year, it should check "no" and should not complete Part III, Column (d), and Part IV.

Line 22: An employer may be eligible to use an alternative reporting method and/or a form of transition relief:

  1. Qualifying Offer Method: An employer is eligible to use this method if it certifies that it made a qualifying offer to at least one full-time employee for all months during the year in which the employee was a full-time employee for whom an employer shared responsibility payment could apply.
  2. Is reserved for future use.
  3. Section 4980H Transition Relief: For the 2016 calendar year, this applies only to coverage under a health plan with a plan year that does not begin on January 1 (i.e., the plan year does not follow the calendar year) and only for calendar months in 2016 that fall within the 2015 plan year. An employer is eligible to use this method if:
    • It is an ALE or ALE member with 50-99 full-time employees (including full-time equivalent employees) on business days in 2014; during the period of February 9, 2014, through December 31, 2014, it did not reduce the size of its workforce or employees' overall hours of service in order to qualify for the transition relief; and during the period of February 9, 2014, through the last day of the 2015 plan year, it did not eliminate or materially reduce the health coverage it offered, if any, as of February 9, 2014; or
    • It is an ALE or ALE member with 100 or more full-time employees (including full-time equivalent employees) on business days in 2014, and it is subject to an employer shared responsibility payment. The assessable payment is calculated by reducing the employer's number of full-time employees by that employer's allocable share of 80.
  4. 98 Percent Offer Method: An employer is eligible to use this method if it certifies that, taking into account all months during which the individuals were employees of the employer and were not in a limited nonassessment period, the employer offered affordable health coverage providing minimum value to at least 98 percent of its employees for whom it is filing a Form 1095-C and offered MEC to those employees' dependents. The employer is not required to identify which of the employees for whom it is filing were full-time employees, but the employer is still required to file Forms 1095-C on behalf of all of its employees who were full-time employees for one or more months of the calendar year. If an employer uses this method, it is not required to complete Part III, Column (b).

Part III - ALE Member Information - Monthly

Lines 23-35 provide summary information of the coverage offered each month.

Column (a): An employer that offered MEC to at least 95 percent of its full-time employees (not including those in a limited nonassessment period) and their dependents for the entire calendar year should check "yes" either on Line 23 for "all 12 months" or for each of the 12 calendar months on Lines 24-35. If the offer was made for only certain months, the employer must check "yes" or "no," as applicable, on Lines 24-35. If an employer did not make such an offer for any of the 12 months, it should check "no" either on Line 23 for "all 12 months" or for each of the 12 calendar months on Lines 24-35. However, an employer that did not make such an offer may check "yes," as applicable, if it qualifies for transition relief (described above in Part II, Line 22).

An employer may check "yes" if it offered MEC to all but five of its full-time employees and their dependents, and five is greater than five percent of the employer's number of full-time employees.

Column (b): The total number of full-time employees does not include those in a limited nonassessment period. If the number of full-time employees is zero, enter the numeral zero.

This column does not need to be completed by an employer that is eligible for the 98 Percent Offer Method (described above in Part II, Line 22).

Column (c): The total number of employees includes full-time and part-time employees and employees in a limited nonassessment period. To determine the number of employees per month, an employer must choose one of the following methods and use it for all months of the year:

  • The first day of each month;
  • The last day of each month;
  • The 12th day of each month;
  • The first day of the first payroll period that starts during each month; or
  • The last day of the first payroll period that starts during each month (provided that, for each month, the last day falls within the calendar month in which the payroll period starts).

If the total number is the same for every month, an employer may enter that number either on Line 23 for "all 12 months" or for each of the 12 calendar months on Lines 24-35. If the number is zero, the employer should enter the numeral zero.

Column (d): An employer that checked "yes" on Part II, Line 21, must complete this column. The employer has the option to check Line 23 or to check some or all of Lines 24-35, as applicable. If any checks are made in this column, the employer must complete Part IV.

Column (e): An employer that selected C on Part II, Line 22 (certifying that it is eligible for Section 4980H Transition Relief), must enter either:

  • Code A, if it is eligible for relief as an employer with 50-99 full-time employees; or
  • Code B, if it is eligible for relief as an employer with 100 or more full-time employees.

The transition relief is available in 2016 only for plans that do not have a calendar-year plan year and applies only to the calendar months in 2016 that fall within the 2015 plan year. Where coverage is offered under more than one health plan with different plan years, the transition relief applies through the last day of the latest of those plan years.

Part IV - Other ALE Members of Aggregated ALE Group

An employer that checked "yes" on Part II, Line 21, must complete this part. If there are more than 30 members of the aggregated ALE group, the employer should only enter the 30 with the highest monthly average number of full-time employees (using the number reported in Part III, Column (b), if a number was required to be reported) for the year or for the number of months during which the ALE member was a member of the aggregated ALE group. The members should be listed in descending order, starting with the member with the highest average monthly number of full-time employees.

If any member of the ALE group uses the 98 Percent Offer Method and, thus, is not required to identify which employees are full-time employees, all aggregated ALE group members should use the monthly average number of total employees, rather than the monthly average number of full-time employees for this purpose.

Step 4: Fill Out Form 1095-C (Information Return)

An ALE must file a Form 1095-C for each employee who was a full-time employee of the employer for any month of the calendar year. Employees in a limited nonassessment period are not considered full-time employees during that period, so reporting is not necessary. An ALE that sponsors a self-insured plan must file a Form 1095-C for each employee (regardless of full-time status) who enrolls in the coverage or enrolls a family member in the coverage.

Part I - Employee / Applicable Large Employer Member (Employer)

Lines 1-6: Require completion of the employee's name, address (including apartment number, if applicable) and Social Security Number (SSN).

Lines 7-13: Require completion of the employer's name and address (including room or suite number, if applicable), the EIN and the telephone number of the person to contact with questions. The employer name, EIN and address used here should match the one used on Form 1094-C.

Part II - Employee Offer and Coverage

Plan Start Month: This box is optional for 2016 and may be left blank. Here, an employer enters the two-digit number indicating the calendar month during which the plan year begins of the health plan in which the employee is offered coverage (or would be offered coverage if the employee were eligible to participate in the plan). If more than one plan year could apply (e.g., the employer changes the plan year during the year), the earliest applicable month should be entered. If there is no health plan under which coverage is offered to the employee, the employer should enter "00."

Line 14: An employer offers health coverage for a month only if the coverage covers every day of that calendar month. An employee who terminates coverage before the last day of the month does not actually have an offer of coverage for that month.

Nine indicator codes specify the type of coverage offered to an employee and his or her spouse (including a same-sex spouse) and dependents. A dependent is a child, including a legally adopted child, who has not reached age 26, but does not include a stepchild, foster child or child living outside the US or a contiguous country and who is not a US citizen or national. An offer of coverage is treated as made to an employee's dependents only if the offer of coverage is made to an unlimited number of dependents regardless of the actual number of dependents, if any, an employee has during any particular calendar month.

The codes, which are used to assess an employee's (and family members') eligibility for premium tax credits for coverage through the exchange, are:

  • 1A: Qualifying Offer.
  • 1B: MEC providing minimum value offered to the employee only.
  • 1C: MEC coverage providing minimum value offered to the employee and at least MEC offered to the employee's dependent(s), but not spouse.
  • 1D: MEC providing minimum value offered to the employee and at least MEC offered to the employee's spouse, but not dependent(s). Code 1J must be entered instead if coverage was offered to the spouse conditionally (i.e., offer is subject to one or more reasonable, objective conditions, such as the spouse is not eligible for coverage under Medicare or another employer's group health plan).
  • 1E: MEC providing minimum value offered to the employee and at least MEC offered to the employee's dependent(s) and spouse. Code 1K must be entered instead if coverage was offered to the spouse conditionally.
  • 1F: MEC not providing minimum value offered to the employee; to the employee and the employee's spouse or dependent(s); or to the employee and the employee's spouse and dependents.
  • 1G: Offer of coverage for at least one month to an employee who was not a full-time employee for any month of the calendar year and who enrolled in self-insured employer-sponsored coverage for one or more months. This code applies to the entire calendar year, so it must be entered in the "All 12 Months" box or in all 12 monthly boxes.
  • 1H: No offer of coverage.
  • 1I: Is reserved for future use.
  • 1J: MEC providing minimum value offered to the employee; MEC conditionally offered to the employee's spouse; and MEC not offered to the employee's dependent(s).
  • 1K: MEC providing minimum value offered to the employee; MEC conditionally offered to the employee's spouse; and MEC offered to the employee's dependent(s).

A code must be entered for each applicable month. However, if the same code applies to all 12 months in the calendar year, the employer may instead enter the code corresponding to the type of coverage offered in the "All 12 Months" box.

A code must be entered for each calendar month, even if an employee was not a full-time employee for one or more of the months. If the employee was not actually offered coverage, the employer must enter code 1H.

The code identifies the type of health coverage actually offered by the employer (or on behalf of the employer) to the employee, if any. A code is not to be entered for any other type of health coverage the employer is treated as having offered, but that the employee was not actually offered, such as under the dependent coverage transition relief or noncalendar-year transition relief, even if the employee is included in the count of full-time employees offered MEC for purposes of Form 1094-C, Part III, Column (a).

For reporting for 2016, an employer relying on the multiemployer arrangement interim guidance should enter code 1H for any month for which the employer enters code 2E on Part II, Line 16 (indicating that the employer was required to contribute to a multiemployer plan on behalf of the employee for that month and, therefore, is eligible for multiemployer interim rule relief). For reporting for 2016, code 1H may be entered without regard to whether the employee was eligible to enroll or enrolled in coverage under the multiemployer plan.

An offer of Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage (or other post-employment coverage) made to a former employee (or the employee's spouse or dependents) upon termination of employment should be reported using code 1H. An offer of COBRA continuation coverage made to an active employee (e.g., due to a reduction in hours rendering the employee ineligible for plan coverage) should be reported in the same manner and using the same code as an offer of that type of coverage to any other active employee.

Line 15: This line should be completed only if code 1B, 1C, 1D, 1E, 1J or 1K is entered on Part II, Line 14, either in the "All 12 Months" box or in any of the monthly boxes. Enter the amount of the employee share of the lowest cost monthly premium for self-only MEC providing minimum value that is offered to the employee.

To determine the monthly employee premium for the plan year, divide the total employee share of the premium for the plan year by the number of months in the plan year. Note that the amount entered is not necessarily the amount the employee is paying for coverage (e.g., the employee may have enrolled in more expensive family coverage).

The reported amount should be decreased by employer flex credits that are made available to the employee through a cafeteria plan that the employee uses to pay for health benefits, or any amount that is made available in an integrated health reimbursement arrangement (HRA) that the employee may use to pay premiums or that the employee may use to pay premiums and also may use for cost-sharing and/or for other health benefits not covered by that plan in addition to premiums.

The reported amount should be increased by the amount of any payment an employee receives to unconditionally opt out of the group plan.

Enter dollars and cents, if applicable. If no employee contribution is required, enter "0.00" - do not leave blank. If the same amount applies to all 12 months, an employer may enter the amount either once in the "All 12 Months" box or in each monthly box. If the amount was not the same for all 12 months, an employer should enter the amount in each calendar month for which the employee was offered minimum value coverage.

Line 16: The codes used here indicate that one of the following situations applied to the employee:

  • The employee was not employed or was not employed full-time;
  • The employee enrolled in the MEC offered;
  • The employee was in a limited nonassessment period;
  • The employer met one of the Section 4980H affordability safe harbors with respect to this employee; or
  • The employer was eligible for multiemployer interim rule relief for this employee.

Only one code may be entered per calendar month. Boxes may be left blank if none of the codes apply for a particular calendar month. If more than one code applies for the same month, code 2C should be used for any month in which an employee enrolled in MEC, instead of any other applicable code. If the same code applies to all 12 months, an employer may enter the code either once in the "All 12 Months" box or in each monthly box.

An employer should understand all of the code descriptions:

  • 2A: To be used if an employee was not employed on any day of the calendar month. Not to be used for a month in which the individual was employed by the employer for any day of the month or for the month in which employment ends.
  • 2B: To be used if an employee was not a full-time employee for the month and did not enroll in MEC, if offered for the month, or was a full-time employee for the month and whose coverage or offer of coverage ended before the last day of the month solely because the employee terminated employment during the month (the coverage or offer of coverage would have continued if the employee had not terminated employment).
  • 2C: To be used if an employee enrolls in coverage offered. Not to be used in any month in which the multiemployer interim rule relief applies (enter code 2E instead). Not to be used if code 1G is entered in the "All 12 Months" box in Line 14 because the employee was not a full-time employee for any months of the calendar year. Also not to be used for any month in which a terminated employee is enrolled in COBRA continuation coverage or other post-employment coverage (enter code 2A instead) or any month in which the employee enrolled in coverage that was not MEC.
  • 2D: To be used for any month in which an employee was in a limited nonassessment period. Also to be used if an employee was in an initial measurement period, rather than code 2B. Not to be used for an employee in a limited nonassessment period for whom the employer is also eligible for the multiemployer interim rule relief for the month (enter code 2E instead).
  • 2E: To be used for any month for which the multiemployer arrangement interim guidance applies for the employee, regardless of whether any other code might also apply. If code 2C, 2F, 2G or 2H also applies, enter code 2E.
  • 2F: To be used if the employer used the Section 4980H Form W-2 safe harbor to determine affordability for the employee for the year. If the safe harbor is used for an employee, it must be used for all months of the calendar year for which the employee is offered health coverage.
  • 2G: To be used if the employer used the Section 4980H federal poverty line safe harbor to determine affordability for the employee for any month(s).
  • 2H: To be used if the employer used the Section 4980H rate of pay safe harbor to determine affordability for the employee for any month(s).
  • 2I: Is reserved for future use.

Part III - Covered Individuals

This part must be completed only if the employer offers employer-sponsored self-insured health coverage (which does not include coverage under a multiemployer plan) in which the employee or other individual enrolled. This part is not to be completed if coverage is offered only under an insured group health plan. If both insured and self-insured coverage is offered, then this part is completed only for employees who enroll in self-insured coverage.

An ALE member with a self-insured major medical plan and an HRA is required to report the coverage of an individual enrolled in both types of MEC coverage under only one of the arrangements. An ALE member with an insured major medical plan and an HRA is not required to report HRA coverage of an individual if the individual is eligible for the HRA because he or she enrolled in the insured major medical plan. An ALE member with an HRA must report coverage under the HRA for any individual who is not enrolled in a major medical plan of the ALE member (e.g., the individual enrolled in a spouse's employer's group health plan).

If the employer is completing Part III, then the checkbox should be marked. If the employer is not completing Part III, then the checkbox should not be marked.

This part must be completed by an employer offering self-insured health coverage for any individual who was an employee for one or more calendar months of the year, whether full-time or not, and who enrolled in the coverage.

If an employee has covered family members on the same plan (e.g., employee elected family coverage), the family members must be included on the same form as the employee.

If spouses (or an employee and his or her dependent) are employed by the same employer, and one employee enrolled in a coverage option under the plan that also covered the other employee, the enrollment information should be reflected only on the Form 1095-C for the employee who enrolled in the coverage (but would report the other employee family member as a covered individual).

This part may be completed by an employer that offers self-insured health coverage for individuals who enrolled in the coverage for at least one calendar month of the year and who were not employees for any calendar month of the year, e.g., a nonemployee director, an employee who retired the previous year, an employee who terminated employment the previous year and is receiving COBRA coverage, a nonemployee COBRA beneficiary (but not including an individual who obtained coverage through the employee's enrollment, such as a spouse or dependent obtaining coverage when an employee elects family coverage under COBRA). An employer that reports on any individual who was not an employee for any month of the calendar year must be sure to complete Part II, Line 14, using code 1G in the "All 12 Months" box or in the box for each individual month.

If a nonemployee individual enrolls in coverage under a self-insured health plan, all family members that are covered due to the individual's enrollment must be included on the same Form 1095-B or Form 1095-C as the individual who is offered, and enrolls in, the coverage.

Columns (a) through (c): Require completion of the names and SSNs of each individual enrolled in the coverage, including the employee reported in Part I, Line 1. For covered individuals who are not the employee, a tax identification number (TIN) may be entered if the covered individual does not have a SSN. Only enter a date of birth in Column (c) if there is no SSN or TIN reported in Column (b).

An employer cannot enter a date of birth before it takes steps to solicit the individual's SSN.

Column (d): An individual is considered to be covered in all 12 months if he or she was covered at least one day per month in each of the 12 months of the calendar year.

Column (e): If an individual was not covered for all 12 months, the employer must check the box(es) corresponding to the month(s) in which the individual was covered for at least one day.

Part III - Covered Individuals - Continuation Sheet

If there are more than six covered individuals, the information for the additional covered individuals must be completed on the continuation sheet(s). Continuation sheets are not included in the count of Forms 1095-C submitted with the accompanying Form 1094-C.

NOTE: Governmental unit employers offering self-insured health coverage that use a DGE for reporting and furnishing enrollment information (i.e., Part III), but have not designated a DGE for reporting and furnishing offers of coverage information (i.e., Part II), should complete Parts I and II, but not Part III, and should not check the box indicating that the governmental unit offers self-insured health coverage. In this case, the DGE should file Forms 1094-B and 1095-B.

Step 5: File Forms With the IRS

Forms 1094-C and 1095-C must be filed with the IRS by February 28 (paper) or March 31 (electronic) of the year following the calendar year to which the return relates. Paper forms must be mailed on or before the due date. If the due date falls on a nonbusiness day (i.e., Saturday, Sunday or legal holiday), the due date is the next business day.

An employer filing 250 or more Forms 1095-C is required to file Forms 1094-C and 1095-C electronically. The employer will receive an electronic acknowledgment once the transaction is completed.

Electronic filers must use the ACA Information Return System (AIR). According to IRS Publication 5164 and Publication 5165, an employer should:

  • Determine the responsible individuals and contacts who will handle the electronic filing;
  • Register with e-services;
  • Complete an Application for Transmitter Control Code (TCC), if the employer acts as an issuer, a software developer and/or a transmitter; and
  • Conduct ACA Assurance Testing System (AATS) testing. Different testing requirements apply depending on whether the employer acts as an issuer, a software developer and/or a transmitter. Software developers must pass AATS testing annually, while issuers and transmitters must do so the first year only.

An employer may apply for a hardship waiver from the electronic filing requirement by filing Form 8508, Request for Waiver From Filing Information Returns Electronically, at least 45 days before the due date of the returns. A waiver is good for only one tax year, so an employer must reapply in subsequent years.

An employer filing fewer than 250 Forms 1095-C may choose to file electronically or on paper. Mailing addresses are as follows:

  • Department of Treasury IRS Service Center, Austin, Texas 73301 (if the employer's legal residence, principal place of business or principal office or agency is located outside of the US or in Alabama, Arizona, Arkansas, Connecticut, Delaware, Florida, Georgia, Kentucky, Louisiana, Maine, Massachusetts, Mississippi, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Ohio, Pennsylvania, Rhode Island, Texas, Vermont, Virginia or West Virginia); or
  • Department of Treasury IRS Service Center, Kansas City, Missouri 64999 (if the employer's legal residence, principal place of business or principal office or agency is located in Alaska, California, Colorado, District of Columbia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Maryland, Michigan, Minnesota, Missouri, Montana, Nebraska, Nevada, North Dakota, Oklahoma, Oregon, South Carolina, South Dakota, Tennessee, Utah, Washington, Wisconsin or Wyoming).

Mailed forms should be sent flat (not folded) via first-class mail. If sending many forms in multiple packages, the employer should write its name on each package, number them consecutively and include Form 1094-C in package number one.

Step 6: Furnish Individual Statements to Employees

To fulfill the individual notice requirement, an employer that is fully insured must furnish a copy of Form 1095-C to each of its full-time employees. An employer that is self-insured must provide a copy of Form 1095-C to every employee who enrolled in coverage, including part-time employees. The individual statements must be furnished by January 31 of the year following the calendar year to which the form relates. If the due date falls on a nonbusiness day (i.e., Saturday, Sunday or legal holiday), the due date is the next business day. Note that for 2016 information reported in 2017 only, the deadline is extended to March 2, 2017.

An employer may truncate SSNs or TINs by showing only the last four digits and replacing the first five digits with Xs or asterisks. EINs may also be truncated. Truncation is not allowed on forms filed with the IRS, however.

Individual statements must be mailed to the recipient's last known permanent address (or temporary address if no permanent address is known), unless the individual has affirmatively consented to electronic receipt.

An employer that is eligible to use the Qualifying Offer Method (see Step 3: Fill Out Form 1094-C, Part II, Line 22) may either give employees a copy of Form 1095-C or a statement containing the following information:

  • Employer name, address and EIN;
  • Contact information and phone number at which the employee can get information about the offer of coverage and the information on Form 1095-C filed with the IRS for that employee;
  • A statement indicating that, for all 12 months of the calendar year, the employee and his or her spouse and dependents, if any, received a qualifying offer and, therefore, are not eligible for a premium tax credit; and
  • A statement directing the employee to see Pub. 974, Premium Tax Credit (PTC), for more information on eligibility for the premium tax credit.

For a full-time employee who, for all 12 months of the calendar year, received a qualifying offer for insured coverage (or a qualifying offer for self-insured coverage in which the employee did not enroll), the employer may provide the information to the employee by furnishing a copy of Form 1095-C as filed with the IRS (with or without the above statement) or may provide only the statement described above.

For a full-time employee who received a qualifying offer and enrolled in self-insured coverage, the employer must furnish the information-reporting enrollment in the coverage on Form 1095-C, Part III. The employer may not use the alternative method of furnishing Form 1095-C under the Qualifying Offer Method for that employee.

For any full-time employee of an employer eligible to use the Qualifying Offer Method (see Step 3: Fill Out Form 1094-C, Part II, Line 22) who receives a qualifying offer for all 12 calendar months and did not enroll in employer-sponsored self-insured coverage, the employer may, instead of giving employees a copy of Form 1095-C, provide a statement containing the following information:

  • Employer name, address and EIN;
  • Contact information and phone number at which the employee can get information about the offer of coverage and the information on Form 1095-C filed with the IRS for that employee;
  • A statement indicating that the employee and his or her spouse and dependents, if any, may be eligible for a premium tax credit for one or more months of 2015; and
  • A statement directing the employee to see Pub. 974, Premium Tax Credit (PTC), for more information on eligibility for the premium tax credit.

For a full-time employee who received a qualifying offer and enrolled in self-insured coverage, the employer must furnish Form 1095-C, including the information-reporting enrollment in the coverage on Form 1095-C, Part III. The employer may not use the alternative method of furnishing Form 1095-C under the Qualifying Offer Method for that employee.

Step 7: Apply For an Extension, If Needed

An employer may receive an automatic 30-day extension for filing returns with the IRS by filing Form 8809, Application for Extension of Time to File Information Returns. The form must be filed with the IRS on or before the due date for Forms 1094-C and 1095-C. An employer may apply for an additional 30-day extension under certain hardship conditions.

In order to receive an extension of up to 30 days for furnishing employee statements, an employer must send a letter to the IRS, Attn: Extension of Time Coordinator, 240 Murall Drive, Mail Stop 4360, Kearneysville, WV 25430. The letter must be postmarked by the due date for the statements and must include:

  • Filer's name, TIN and address;
  • Type of return;
  • A statement that the extension request is for providing statements to recipients;
  • Reason for the delay; and
  • Signature of the filer or authorized representative.

Step 8: File Corrected Forms, If Needed

If Form 1094-C needs to be corrected, the employer should file a fully completed Form 1094-C with an X in the "Corrected" checkbox. An employer should not file a return correcting information on a Form 1094-C that is not the Authoritative Transmittal. No other documents (e.g., Form 1095-C) may be filed with the corrected Authoritative Transmittal.

If Form 1095-C needs to be corrected, the employer should file a fully complete Form 1095-C with an X in the "Corrected" checkbox. Form 1094-C should be filed with the corrected Form 1095-C; however, the "Corrected" checkbox should not be marked on Form 1094-C. A copy of the corrected Form 1095-C must also be furnished to the employee, unless the employer is eligible to use the Qualifying Offer Method.

If Form 1095-C has been furnished to the employee but has not yet been filed with the IRS, then the "Corrected" checkbox need not be marked. The employer should write "Corrected" on the new Form 1095-C furnished to the employee.

If an employer eligible to use the Qualifying Offer Method had furnished the employee an alternative statement, then the employer must furnish the employee a corrected statement if it filed a corrected Form 1095-C correcting the employer's name, EIN, address or contact name and telephone number. If the employer is no longer eligible to use an alternative furnishing method for the employee, then it must give the employee a Form 1095-C and advise the employee that the form replaces the statement it had previously provided.

Instructions for making corrections to electronically filed forms are found in Publication 5165.

Step 9: Maintain Documentation

An employer must keep copies of information returns filed with the IRS, or maintain the ability to reconstruct the data, for a minimum of three years from the due date of the returns.