Instructions for Filling Out Form 1094-C

Discover the essentials of Form 1094-C, a crucial document for employers reporting health insurance coverage under the Affordable Care Act (ACA). This article offers a concise overview of the form and a step-by-step guide on completing it accurately and efficiently.

In this article, we'll provide information on Form 1094-C and a step-by-step guide on how to fill it out.

What is Form 1094-C?

Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, is a document used by employers to report summary information for each Applicable Large Employer (ALE) member and to transmit Forms 1095-C to the IRS. Employers with 50 or more full-time employees (including full-time equivalent employees) in the previous year use Forms 1094-C and 1095-C to report information required under sections 6055 and 6056 about offers of health coverage and enrollment in health coverage for their employees. These forms play a crucial role in determining whether an ALE Member owes a payment under the employer shared responsibility provisions under section 4980H and the eligibility of employees for the premium tax credit.

Who Must File Form 1094-C?

Applicable Large Employer Members (ALE Members) are required to file Form 1094-C. An ALE Member is typically a single person or entity that is an Applicable Large Employer or, if applicable, each person or entity that is a member of an Aggregated ALE Group. Generally, an Applicable Large Employer is an employer with 50 or more full-time employees (including full-time equivalent employees) in the previous year. ALE Members must file one or more Forms 1094-C, including a Form 1094-C designated as the Authoritative Transmittal, and a Form 1095-C for each employee who was a full-time employee for any month of the calendar year. They are also generally required to furnish a copy of Form 1095-C (or a substitute form) to the employee.

Form 1094-C Tax Filing Deadlines and Due Dates

• File by February 28, 2024, if filing on paper for the calendar year 2023
• File by April 1, 2024, if filing electronically for the calendar year 2023

Form 1094-C Late Payment Penalty

Employers who fail to file Form 1094-C or furnish correct statements by the due date may face penalties. The specific penalty amounts are subject to change and can be found in other IRS publications or sections of the IRS website. It is crucial for employers to stay updated on the latest penalty information to avoid any potential financial consequences.

Step-by-Step Instructions for Form 1094-C

Step by Step Instructions for Filling Out Form 1094-C:

1. Part I - Applicable Large Employer Member (ALE Member):
   • Line 1: Enter the employer's name.
   • Line 2: Enter the ALE Member’s EIN.
   • Lines 3-6: Enter the ALE Member’s complete address.
   • Lines 7 and 8: Enter the name and telephone number of the person to contact.
   • Line 9: If a Designated Governmental Entity (DGE) is filing on behalf of the ALE Member, enter the name of the DGE.
   • Line 10: Enter the DGE’s EIN.
   • Lines 11-14: Enter the DGE’s complete address.
   • Lines 15 and 16: Enter the name and telephone number of the DGE contact person.
   • Line 17: Reserved for future use.
   • Line 18: Enter the total number of Forms 1095-C submitted with this Form 1094-C transmittal.
   • Line 19: Check the box if this Form 1094-C transmittal is the Authoritative Transmittal.
2. Part II - ALE Member Information:
   • Lines 20-22: Provide information about the ALE Member, including the total number of Forms 1095-C filed and whether the ALE Member was part of an Aggregated ALE Group.
3. Part III - ALE Member Information—Monthly:
   • Lines 23-35: Fill in information about the offer of coverage, full-time employee count, total employee count, and aggregated group indicator for each month.
4. Part IV - Other ALE Members of Aggregated ALE Group:
   • Lines 36-65: If applicable, list up to 30 other ALE Members of the Aggregated ALE Group, including their names and EINs.

The instructions also emphasize the importance of reporting accurately to determine employer shared responsibility payments and employees' eligibility for premium tax credits.

How to Submit Form 1094-C

To submit Form 1094-C, file it as the transmittal document for Forms 1095-C, including aggregate employer-level data for all full-time employees. Designate one form as the Authoritative Transmittal if filing more than one Form 1094-C. Complete all required parts of the form, sign and date it, and submit it by the due date. If required to file 10 or more information returns, file the forms electronically. Ensure accuracy, deadline compliance, and retain copies of the filed forms for at least 3 years from the due date.

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