What are Forms 1094-C and 1095-C?

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.

In shortForms 1094-C and 1095-C are the information returns applicable large employers use under the Affordable Care Act. The IRS instructions say an applicable large employer is generally an employer with 50 or more full-time employees, including full-time equivalent employees, in the previous year. A full-time employee for this purpose averages at least 30 hours of service a week. For each full-time employee, the employer completes a Form 1095-C showing, month by month, whether coverage was offered, the cost of the lowest-priced self-only option, and the code that explains the offer or why none was made. Form 1094-C is the summary that goes with them, with counts of employees and whether the employer offered coverage to enough full-time employees. According to the IRS, the returns are filed by February 28, or March 31 if filed electronically, of the year after the calendar year they cover. The general rule is that Form 1095-C is furnished to employees by January 31. Recent IRS guidance also allows an alternative: in place of sending the form automatically, an employer can post a clear, conspicuous and accessible notice on its website that individuals may request a copy, and then furnish it within the set time after a request. Employers should check the current instructions for when that option applies. The data behind these forms is hours, so the quality of time records decides the quality of the report.

What the forms show

1094-C and 1095-C
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.

Average weekly hours in the measurement periodHired asabout 26 hMeasured31.5 h, full-time30 hThe hours, not the title, decide
An employee who averages 30 or more hours is full-time for the ACA, whatever the title.

Worked example: a variable-hour employee

A server whose hours went up

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.

Mistakes that are specific to Forms 1094-C and 1095-C

Where the monthly data comes from

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.

Second example: a new full-time hire and the waiting period

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.

Track hours monthly, not in JanuaryRun a monthly report of average weekly hours for every variable-hour employee. Anyone trending above 30 is a coverage decision you can make in time, instead of a reporting surprise.

Questions people ask

Who has to file Form 1095-C?

Applicable large employers, generally those with 50 or more full-time employees including full-time equivalents in the previous year.

What is the difference between Form 1094-C and Form 1095-C?

Form 1095-C reports coverage offers for one employee. Form 1094-C is the employer’s transmittal and summary filed with them.

When are Forms 1094-C and 1095-C due?

To the IRS by February 28 on paper or March 31 electronically. To employees generally by January 31, unless the alternative notice method applies.

Do I need Form 1095-C to file my taxes?

Usually not. Employees generally do not need to wait for it to file their return.

What counts as an hour of service for the ACA?

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.

Can a new full-time employee have a waiting period before coverage?

Yes, but a waiting period cannot be longer than 90 days.

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Disclaimer: This explanation of Forms 1094-C and 1095-C is general information, not legal, payroll or tax advice; rules differ by state and city and change over time, and the examples are fictional.