Article Highlights:

  • Forms 1094-C and 1095-C
  • Applicable Large Employer
  • Forms’ Purpose
  • Filing Due Dates

Beginning in 2015, Applicable Large Employers are required to file a new informational return – 1095-C, Employer-Provided Health Insurance Offer and Coverage. One of these informational returns must be provided to each full-time employee and filed with the IRS, along with a Form 1094-C transmittal form, by the due dates listed below.

An Applicable Large Employer is an employer with 50 or more full-time employees, including full-time equivalent employees. Applicable Large Employers are required to report information to full-time employees and the IRS about the coverage they offered or did not offer to their full-time employees. It is important to understand that Applicable Large Employers are required to file the 1094-C and 1095-C forms Regardless of whether or not they offered their full-time employees insurance, even if they were exempt from the insurance mandate for 2015 because they employed fewer than 100 full-time and full-time equivalent employees.

The purpose of the new form is twofold: (1) to provide the IRS with information it needs to determine if the employee is eligible for the Premium Tax Credit and (2) to provide the IRS information it needs to determine the employer’s health coverage excise tax (the penalty for not offering affordable care to its full-time employees), if any.

All employers need to complete parts I and II of the 1095-C for each full-time employee. Self-insured employers must also complete part III, which is the information that would be included on a Form 1095-B issued to the employer’s employees by group health insurance companies when the employer is not self-insured.

Due Dates:

  • Form 1095-C to employees:                           March 31
  • 1095-C and 1094-C filed with the IRS:
    o Paper filed:                                              May 31
    o E-filed:                                                     June 30
Note: If the employer files 250 or more 1095-Cs, the forms must be electronically filed.

If you need additional information related to this filing requirement or assistance with filing these forms, please contact this office as soon as possible as the due date is drawing close.

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