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Who Needs to File Forms 1094 and 1095?

Form 1095-C

Here’s something you probably already know: If you’re an employer with 50 or more employees (or full-time equivalents), you are required under the Affordable Care Act to offer health insurance coverage to at least 95 percent of your full-timers and their dependents. 

Here’s something you may not know: You are also required to report this coverage to both your employees and the IRS. 

What can we say? Growing up means more responsibility! 

We’re talking about Forms 1094 and 1095, but you may see this type of reporting referred to by other numbers: 6055 and 6056. The IRS is in charge of making sure that everyone has health insurance, or pays a penalty, and that all large employers must offer health care coverage, or, you guessed it, pay a penalty. Governed by Sections 6055 and 6056 of the ACA, the IRS monitors health care usage through Forms 1094 and 1095.

The 1094 and 1095 are a package deal. Form 1095 provides information about the health insurance elected by each employee. This form gets sent to both employees and the IRS. Think of the 1095 as the W-2 reporting for health insurance. And Form 1094 is essentially a cover sheet for the 1095 and only needs to be sent to the IRS. 

But we’re dealing with the IRS here, so it’s not that simple. There are actually three forms involved with the 1095: 

  • Health exchanges send Form 1095-A  
  • Insurance carriers send Form 1095-B  
  • Self-insured employers send Form 1095-C  

As a large employer, you want to focus on Forms 1094-C and 1095-C. As an aside: Technically, Form 1094-C is called Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns. See why the IRS uses form numbers?  

Form 1094-C includes: 

  • Employer’s address, phone number, EIN
  • Contact person
  • Number of 1095-Cs being submitted
  • Certifications of eligibility
  • Aggregated group members

Form 1095-C includes: 

  • Health care coverage offered 
  • Lowest-cost premium available to employee
  • Which months coverage was available 

When are they due? 

Unlike in 2021 when the IRS extended the deadline to send 1094-C and 1095-C forms to employees, there was no extension to the mailing deadline in 2022. Employers have until the customary date of Jan. 31 to mail these forms. The deadlines for filing with the IRS are Feb. 28 for paper filers and March 31 for electronic filers. Paper copies must be mailed to employees, unless they opt in to receiving them electronically. 

Currently, employers who submit at least 250 of these forms must file electronically here. However, a proposed change would reduce that threshold to 100 in 2022 and just 10 in 2023 and beyond. The rule would also require employers to aggregate all of the forms they are submitting.

After all of this, we don’t blame you if you have questions. If so, we’re here to help: (724) 349-1919. And, hey, if you like what you see here, bookmark this page. 

You may also want to read: What is a 1094/1095 Form?

Jason Levan

Jason Levan joined Kuzneski Insurance Group in 2021 as Director of Communications and Content after his first career as a newspaper reporter and editor. In Act II, he oversees the content marketing for the company, with the goal of making the insurance world easier to understand and navigate for our clients. When he’s not at work, you can often find him “banging and clanging” in the gym, or spending time with his family.

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