Forms 1094-C and 1095-C are the ACA reports that applicable large employers file to show the IRS which full-time employees were offered health coverage, month by month. Form 1095-C covers one employee. Form 1094-C is the transmittal that covers the whole employer.
| Form | Covers | Main content |
|---|---|---|
| Form 1095-C | One employee | Offer of coverage by month, lowest self-only cost, codes |
| Form 1094-C | The employer | Counts of employees, offer of coverage to full-time employees, totals |
| Deadline to file with the IRS | Both | February 28 on paper, March 31 electronically |
| Deadline to furnish employees | Form 1095-C | January 31, or the alternative notice method where it applies |
See full-time hours for the 30-hour test and FTE for counting full-time equivalents.
EZTime digital HR forms let you send, sign and file employee documents online.
A restaurant group with 85 employees is an applicable large employer. A server hired as part-time works 24 to 28 hours a week for most of the year, so she is not offered coverage.
In the group’s measurement process, her average over the measurement period comes out at 31.5 hours a week, above the 30-hour line. She is therefore treated as full-time for the following stability period, and the group offers her coverage starting in January.
Her Form 1095-C for the next year shows an offer of coverage in each month with the matching code and her lowest self-only cost. If the group had looked only at her part-time title, it would have missed the offer, and the 1094-C count of full-time employees would have been wrong. The hours came straight from the time clock, which made the measurement easy to defend.
Each line of Form 1095-C depends on monthly facts: whether the employee was full-time that month, whether coverage was offered, and what the lowest-cost self-only option cost the employee. Full-time status comes from hours of service, which include hours worked and hours paid for time off such as vacation, holidays and sick leave.
That makes time records part of ACA reporting. Keep hours of service for every employee, not only those you consider full-time, because a part-timer whose hours rise can become full-time under the measurement method you use. A new full-time employee can have a waiting period before coverage starts, but it cannot be longer than 90 days.
The restaurant group hires a full-time kitchen manager on March 9. Its plan has a waiting period that ends on the first day of the month after 60 days, so coverage is offered from June 1, within the 90-day limit.
On her Form 1095-C, the months before her start show no employment, the waiting period months use the code the instructions give for that situation, and June through December show the offer of coverage and her monthly cost. Payroll checks that the months line up with her start date in the employee file before filing.
Applicable large employers, generally those with 50 or more full-time employees including full-time equivalents in the previous year.
Form 1095-C reports coverage offers for one employee. Form 1094-C is the employer’s transmittal and summary filed with them.
To the IRS by February 28 on paper or March 31 electronically. To employees generally by January 31, unless the alternative notice method applies.
Usually not. Employees generally do not need to wait for it to file their return.
Each hour an employee is paid or entitled to payment for work, plus paid hours of time off such as vacation, holidays and sick leave.
Yes, but a waiting period cannot be longer than 90 days.
EZTime turns clock-ins and approved corrections into signed monthly reports you can export to PDF or Excel for payroll.