How do I complete the 1094-C?

Completing the 1094-C

Part I: Applicable Large Employer Member (ALE Member)

Part I of the 1094-C form includes the payer information that was entered into the Yearli program. This information will be automatically entered on the form based on what was entered in the program.

Part II: ALE Member Information

Line 19: Authoritative or non-authoritative?

There are two versions of the 1094-C form: an authoritative copy, and a non-authoritative copy. Only one authoritative 1094-C form will be filed per company, per tax year. The authoritative 1094-C will need to be filed with a batch of 1095-C forms; it cannot be filed by itself.

Note: There will need to be one authoritative 1094-C form filed per EIN. If the employer is part of an Aggregated ALE Group, each specific EIN in that Aggregated ALE Group will need their own authoritative 1094-C form.

If you are only filing one batch of 1095-C forms for the company, the 1094-C form that is included with that batch will be the authoritative 1094-C. The only reason a non-authoritative 1094-C will need to be filed would be if multiple batches of 1095-C forms were filed for the company.

For example, if ABC Company has 300 full-time employees, and they are filing all 300 1095-C forms at the same time, the 1094-C form that is included with that batch of 1095-C's will be the authoritative 1094-C. If ABC Company decided to file 3 batches of 100 1095-C forms instead, only one of those batches of 1095-C forms would have an authoritative 1094-C included. The other two batches in this scenario would have non-authoritative 1094-C forms included.

Parts II, III, and IV are only required if the 1094-C being filed is an authoritative 1094-C. If the 1094-C is a non-authoritative transmittal, only Part I is required.

Line 20: Total number of Forms filed by and/or on behalf of ALE Member

Enter the total number of 1095-C forms that will be filed by and/or on behalf of the employer, regardless of how many batches are being filed. If you are filing all of the 1095-C forms for a company at the same time, this number will likely be the same number entered on line 18.

Note: This value is based on the total number of 1095 forms filed on behalf of the employer, not the Aggregated ALE Group. The number here will reflect the total number of 1095-C forms being filed for the specific employer entered in Part I of the 1094-C form.

Line 22: Certifications of Eligibility

Certifications of Eligibility offer employers the opportunity to indicate that they are eligible for three different kinds of relief. Check all boxes that apply.

  • Box A, Qualifying Offer Method, should be checked if the employer entered Code 1A on Line 14 (Offer of Coverage) of Form 1095-C indicating that a qualifying offer was made to one or more full-time employees for all months in which the employee was a full-time employee for whom an employer shared responsibility payment could apply.
  • Box B - Reserved.
  • Box C, Section 4980H Transition Relief, should be checked if the employer had 50-99 full-time equivalent employees in 2014 and did not reduce the size of its workforce or overall hours of service of its employees, and did not eliminate or materially reduce health coverage. Employers that check Box C to certify this scenario should also enter Code A in the column titled “Section 4980H Transition Relief Indicator” in Part III.
  • Box C should also be checked by employers that had 100 or more full-time equivalent employees in 2014. Employers that check Box C to certify this scenario should also enter Code B in the column titled “Section 4980H Transition Relief Indicator” in Part III. Checking box C will reduce or eliminate any Section 4980H penalty.
  • Box D, 98% Offer Method, should be checked if the employer offered for all months affordable health coverage providing minimum value to at least 98% of its employees for whom it is filing Form 1095-C and offered minimum essential coverage to these employee’s dependents. Employers that check Box D are not required to complete the “Full Time Employee Count for ALE Member” column in Part III.

Note: The 1094-C does not need to be signed when filing electronically.

Part III: ALE Member Information - Monthly

Part III requires the ALE to report month-by-month data for several items. Completing Part III is required for all employers, unless this is not the authoritative transmittal. If this is not the authoritative transmittal, Part III should not be completed.

Minimum Essential Coverage Offered Indicator

If at least 95% of full-time employees and their dependents were offered Minimum Essential Coverage, check this box. Employees in a Limited Non-Assessment Period are not included in this determination. Note that other transition relief applies. Please see page 8 and pages 16-17 of the IRS instructions for details.

Section 4980H Full-Time Employee Count for ALE Member:

Enter the number of full-time employees for each month.

  • Include all employees determined to be ACA Full-Time employees.
  • Do not count employees in a Limited Non-Assessment Period.
  • If the number is zero, enter "0".
  • If Box D on Line 22 (Certifications of Eligibility) of Form 1094-C is checked, do not complete this column.
  • Only use the "All 12 Months" row if the number of full-time employees did not fluctuate throughout the year. If the number of full-time employees changed throughout the year, leave the "All 12 Months" row blank and enter a number for each individual month.

Total Employee Count for ALE Member:

Enter the number of employees, including full-time employees, non-full-time employees, and employees in a Limited Non-Assessment Period for each month. If the number is zero, enter “0”. An employer must choose to use one of the following days to determine the number of employees per month and must use the same day for all months of the year:

  • First day of the month
  • Last day of the month
  • 12th day of the month
  • First day of the first payroll period that starts during each month
  • Last day of the first payroll period that starts during each month (provided that for each month that last day falls with the calendar month in which the payroll period starts)

Note: Only use the "All 12 Months" row if the total number of employees did not fluctuate throughout the year. If the number of employees changed throughout the year, leave the "All 12 Months" row blank and enter a number for each individual month.

Aggregated Group Indicator:

Check the months in which the employer was a member of an Aggregated ALE Group. An ALE Group is two or more companies that have a common owner or are otherwise related.

Section 4980H Transition Relief Indicator:

This column must be completed if Box C on Line 22 (Certifications of Eligibility) of Form 1094-C is checked. If Box C on Line 22 is not checked, leave this column blank.

  • Enter Code A in this column if the employer had 50-99 full-time equivalent employees in 2014 and did not reduce the size of its workforce or reduce the overall hours of service of its employees and did not eliminate or materially reduce health coverage.
  • Enter Code B in this column if the employer had 100 or more full-time equivalent employees in 2014.

Part IV: Other ALE Members of Aggregated ALE Group

If the employer is a member of an Aggregated ALE Group in Part II, complete this section. If the employer is not a member of an Aggregated ALE Group, this section is not required and will not be displayed.

Enter the name and EIN of up to 30 of the other Aggregated ALE Group members. If there are less than 30 ALE Group members, the data can be entered in any order. If there are 30 or more members, enter the names of those members with the highest monthly average number of full-time employees for the year or for the number of months during which the ALE Member was a member of the Aggregated ALE Group. Enter in descending order listing the member with the highest average monthly number of full-time employees first. 

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