E-File 1094-C
What is ACA Form 1094-C?
ACA Form, 1094-C "Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns," is an essential form used by Applicable Large Employers (ALEs) under the Affordable Care Act (ACA). Its primary functions and features include:
- Transmittal of Information Returns: Form 1094-C serves as a cover sheet for transmitting Form 1095-C information returns to the IRS. ALEs use Form 1095-C to report details about the health insurance coverage offered to full-time employees, and Form 1094-C helps to summarize and transmit this information.
- Reporting Aggregate Employer-Level Data: In addition to transmitting Form 1095-C returns, Form 1094-C includes aggregate information about the employer, such as total employee count, full-time employee count, and information about offers of coverage.
- Supporting Compliance with Employer Mandate: The information reported on Form 1094-C assists the IRS in enforcing the ACA's employer mandate, which requires ALEs to offer affordable, minimum essential coverage to full-time employees or potentially face penalties.
- Indicating Transitional Relief or Other Options: Employers may use Form 1094-C to indicate eligibility for specific transitional relief or other options available under the ACA.
In summary, Form 1094-C is a critical component of the ACA's reporting requirements for large employers. Proper completion and timely submission of this form are vital for compliance with healthcare regulations and to avoid potential penalties.
What information is required to file form 1094-C?
When filing ACA Form 1094-C, "Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns," Applicable Large Employers (ALEs) must provide the following information:
- Employer Information: Includes the employer's name, Employer Identification Number (EIN), address, and contact details.
- Aggregated Employer Group Information: If the employer is part of an aggregated employer group, information about other entities in the group must be provided.
- Total Number of 1095-C Forms: The number of 1095-C forms being transmitted with the 1094-C form.
- Total Employee Count: Information about the total number of employees, including both full-time and part-time employees.
- Full-Time Employee Count: The number of full-time employees for each month of the year.
- Information About Offers of Coverage: Details about the health coverage offered, including whether Minimum Essential Coverage (MEC) was offered to full-time employees and their dependents.
- Transitional Relief and Other Options: Indication of any transitional relief or other options that the employer is using under the ACA.
- Signature: An authorized signature, attesting to the accuracy of the information provided.
Properly completing Form 1094-C is essential for compliance with the ACA's reporting requirements for large employers.
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When is the deadline to submit form 1094-C?
The deadlines for submitting ACA Form 1094-C, "Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns," vary based on the method of filing:
- Electronic Filing: If filing electronically, the deadline is generally March 31st of the year following the calendar year to which the information relates. Electronic filing is mandatory for Applicable Large Employers (ALEs) that are filing 10 or more Form 1095-C returns.
- Paper Filing: If filing on paper (permitted for those submitting fewer than 10 Form 1095-C returns), the deadline is typically February 28th of the year following the calendar year to which the information relates.
These deadlines are subject to change, and it's essential to consult the IRS instructions or the IRS website for the most current information. Missing the deadline can result in penalties, so timely filing is critical. Employers may also explore the possibility of obtaining an extension if needed.
E-file Form 1094-C
What is the penalty for not submitting form 1094-C?
Failure to submit ACA Form 1094-C, "Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns," or submitting it with incorrect information, can result in penalties. The specific penalties may include:
- Penalty for Failure to File: A penalty may be assessed for failing to file Form 1094-C by the required deadline. For tax year 2023, this penalty is generally $310 per return, with a maximum annual penalty of $3,783,000
- Penalty for Incorrect Information: If Form 1094-C is filed with incorrect or incomplete information, there may be a penalty. This penalty is also generally $310 per return, with the same maximum, if the error is not corrected within the required time frame.
- Intentional Disregard: If the failure to file is due to intentional disregard of the filing requirements, the penalty per return is greater, with no maximum limit.
- Adjustments for Smaller Businesses: Lower maximum penalties may apply to organizations with gross receipts of $5 million or less.
- Possible Penalty Abatement: Penalties may be abated if the failure was due to reasonable cause and not willful neglect.
It's essential to note that these penalties are subject to change. Timely and accurate filing of Form 1094-C is crucial to avoid these penalties.
What are the ICHRA reporting requirements?
Individual Coverage Health Reimbursement Arrangements (ICHRAs) are subject to specific reporting requirements under the Affordable Care Act (ACA). Employers offering ICHRAs must adhere to the following reporting obligations:
- Form 1095-B or Form 1095-C: Depending on the size of the employer and whether the employer offers other group health plans, employers must report information about the ICHRA on either Form 1095-B or Form 1095-C.
- Section 6055 Reporting: Under Section 6055, employers must report information about the individual coverage that is provided to employees, including information about the coverage and the covered individuals.
- Section 6056 Reporting: Applicable Large Employers (ALEs) offering ICHRAs must also comply with Section 6056 reporting, providing information about the offers of coverage made to full-time employees.
- Employee Notice: Employers must provide a notice to eligible employees with details about the ICHRA, including the amount of the benefit, terms and conditions, and how the ICHRA affects premium tax credit eligibility.
- Documentation: Employers must keep records of all offers, reimbursements, and other ICHRA-related activities for at least three years, as this information may be required for IRS review or employee inquiries.
The specific reporting requirements for ICHRAs can be complex and are subject to change.
What are the state filing requirements for Form 1094-C?
State filing requirements for ACA Form 1094-C, "Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns," may vary widely among states. Key considerations include:
- State-Specific Mandates: Some states have enacted their own health insurance reporting mandates, requiring additional or separate filing of forms similar to Form 1094-C. These mandates may align with federal requirements or differ in significant ways.
- Alignment with Federal Requirements: In states that have aligned their reporting requirements with federal ACA standards, employers may be required to file copies of Form 1094-C with the state, following similar guidelines as for federal filing.
- Electronic Filing: Some states may require or offer electronic filing of ACA-related forms, and the process and deadlines may differ from federal requirements.
- Penalties: Failure to comply with state-specific filing requirements can result in penalties, which vary by state and may be in addition to federal penalties.
- Applicability: State filing requirements may apply differently based on factors such as the size of the employer, the type of coverage offered, and other criteria defined by the state.
Due to the potential complexity and variability of state filing requirements for Form 1094-C, employers should consult state regulations, guidance, and possibly seek legal or tax professional assistance to ensure compliance with all applicable state requirements.
Which states that have ACA reporting requirements?
Several states have implemented or were considering their own health coverage reporting requirements, which may include filings similar to or in addition to ACA Form 1094-C. Some of these states include:
- California: California has implemented its own state-level individual mandate and requires certain reporting from employers.
- New Jersey: New Jersey's state-level individual mandate includes reporting requirements for employers and coverage providers.
- Massachusetts: Massachusetts has longstanding reporting requirements related to health coverage, including employer reporting.
- Washington, D.C.: The District of Columbia has also implemented a local individual mandate with associated reporting requirements.
- Rhode Island: Rhode Island has enacted a state-level individual mandate that includes specific reporting obligations.
- Vermont: Vermont has considered health coverage reporting requirements that may affect employers and coverage providers.
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