Clearing ACA Confusion: Which Employers Must File IRS Forms 1095-C/1094-C?

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Forced Minority Burdened Majority comparison_Integrity Data ACA Compliance SolutionWhen awareness of penalty risks under the Affordable Care Act kicked in, back in 2012, employers came to us looking for help.


Those employers were the Forced Minority. Offering little to no coverage, they knew they had a range of must-dos on their road to compliance with the new federal mandate to provide health insurance of a certain quality, at a certain price, to certain employees – those who are full-time.


Seeking ways to reduce those penalty risks, they had to know: Whom to cover. How to calculate “full-time.” How to get offers out fast. What to offer. How to test if an offer is “affordable.” How to keep records. What records to keep.


Before any mention of the IRS reporting component to ACA compliance, these employers were already overwhelmed.


Waking up the ACA Burdened Majority


Now that we’re approaching the first ACA filing season, we’re finding a new group of employers vulnerable to penalties under the new health law. We call these employers the Burdened Majority.


When we alert members of the Burdened Majority to their lesser-known ACA penalty risk, they too are overwhelmed.

Confusion between ACA coverage compliance and IRS reporting compliance


Employers in the Burdened Majority believe their compliance with the coverage mandate spares them from meeting the IRS requirement for ACA reporting: “That’s just for everyone else, right?”




If you are an employer in any of the U.S. states and have 50 or more full-time employees, including full-time equivalents, you must report both to your employees and to the IRS a range of details about access to employer-sponsored health insurance at your workplace. The new IRS forms for doing this super-detailed ACA reporting are the 1095-C and the 1094-C.


Not filling out these forms is the ACA risk for employers in the Burdened Majority.




For what can be viewed as intentional disregard of an information reporting requirement, these employers face a penalty of up to $500 per required return if they do not produce Form 1095-Cs for their employees and then file their transmittal, Form 1094-C, with the IRS.


In clearing ACA confusion: Which employers must file? please review flowcharts in the following flipbook for compliance must-knows. (To read full-screen, use the far-left button. To download, use the third-from-the-left button.)


Year-end workforce reporting: Redefined and intensified


This is the most stringent employer reporting to date. Even when you are complying with the spirit of the law, it’s easy to feel you’re not ready to comply with the letter of the law.


According to ACA regulations, employers must track hours of service to the employer – not just hours paid on the job – in accounting for an employee’s full-time status. Tracking of employee hours of service applies to exempt as well as non-exempt workers. Employee coverage offers and coverage accepted must be tracked as well. Moreover, size matters. Have 250 or more Form 1095-C submissions? Filing must be done electronically.


As an employer, you must re-orient your thinking about year-end reporting to monthly breakdowns – intricately detailed monthly breakdowns.

Heavy lifting for the ACA compliance burden – for any ERP or payroll system


Deadlines might seem far off, but they are not. Production and filing deadlines for IRS Form 1095-C mirror those for Form W-2, but this form is not as easy to produce and it does not necessarily go to every employee.


Wait until the last minute, and you could be swamped, late and penalized for not declaring compliance measures that you already had exceeded!


Integrity Data's trusted software and coaching for ACA reporting can make compliance with the IRS reporting requirements of the Affordable Care Act a non-issue. In just a day's time for deployment, you can break out of the Burdened Majority.


By Helen Karakoudas | ACA Education Director, Integrity Data

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