If you’re an employer who’s required to offer health insurance to employees, you may be familiar with Form 1095-C. But, how much do you know about Form 1095-C’s counterpart, IRS Form 1094-C? Get the inside scoop on what is Form 1094-C, how it differs from a 1095-C form, and more.

IRS Form 1094-C: Q&A

Looking for an in-depth look at Form 1094-C? You’ve come to the right place. Check out all of the answers to your must-asked question below. 

What is Form 1094-C?

IRS Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and

Coverage Information Returns, is a transmittal form you must send along with Forms 1095-C to the IRS each year. 

Form 1094-C is basically a cover sheet for Forms 1095-C that breaks down:

• Employer information (e.g., business name, address, etc.)
• Number of employees
• Number of Forms 1095-C sent to the IRS
• Contact information for the employer

In short, Form 1094-C is a summary form applicable large employers (ALEs) must send to the IRS each year when filing Form 1095-C.

What’s the difference between Form 1094-C vs. Form 1095-C?

Form 1095-C, or Employer-Provided Health Insurance Offer and Coverage, is a form ALEs must file that provides information on employer-sponsored health insurance offered to employees, their spouses, and dependents. A 1095-C form allows the IRS to track which employers are making coverage available to employees. 

Employers must send a copy of Form 1095-C to employees and the IRS each year regardless of whether they enroll in the company’s healthcare plan. With Form 1094-C, the employer only needs to send it to the IRS. 

Who files a 1094-C form?

As mentioned, employers who are considered applicable large employers must send a 1094-C form to the IRS. So, what is an ALE exactly?

An applicable large employer employs 50 or more full-time employees. Under the Affordable Care Act (ACA), ALEs need to report if they’ve offered health coverage to each employee and which employees are enrolled in healthcare coverage. This is where Form 1094-C comes into play.

If your business has less than 50 employees, you’re not quite off the hook when it comes to Form 1094-C. If your company provides employer-sponsored health insurance, you still have to file the form.

What’s included on the form?

There are a few sections you need to fill out on Form 1094-C. These include:

• Part I: Applicable Large Employer Member (ALE Member)
  • Employer name
  • Employer Identification Number (EIN)
  • Address
  • Name of person to contact
  • Phone number
  • Name of Designated Government Entity (if applicable)
  • Number of Forms 1095-C submitted with the form
  • Authoritative transmittal for the ALE member
• Part II: ALE Member Information
  • Number of Forms 1095-C filed by and/or on behalf of ALE Member
  • Member of an Aggregated ALE Group
  • Certifications of Eligibility
  • Signature, title, and date
• Part III: ALE Member Information—Monthly
  • Indicate whether your company offered minimum essential coverage to at least 95% of full-time employees for the calendar year
• Part IV: Other ALE Members of Aggregated ALE Group
  • Enter the names and EINs of other ALE members of the Aggregated ALE Group from the year

To complete the form, make sure you have applicable information handy, like your EIN, number of Forms 1095-C, number of employees, ALE member details, and coverage information. You can keep this information organized in your payroll records. You can also opt to use HR software to keep track of documents with employee and company information.

Some of the sections ask you questions, like “Is this the authoritative transmittal for this ALE Member?” or “Is ALE Member a member of an Aggregated ALE Group?” If you’re unsure how to fill out the form or have questions, contact the IRS or check out the Form 1094-C Instructions.

What is the form’s deadline?

Due dates for the form can vary. Here’s a breakdown of each Form 1094-C IRS deadline to keep in mind:

• Paper filing: February 28
• Electronic filing: March 31

If the due date falls on a weekend or holiday, the deadline falls on the next business day instead.

Be sure to double-check the due date during tax time to ensure you send copies to the IRS on time. 

Where do you send Form 1094-C?

Again, unlike Form 1095-C, you only have to send Form 1094-C to the IRS each year. Do not send a copy of Form 1094-C to your employees. Only send a copy of the form to the IRS by the applicable deadline. 

You can either file the form electronically or fill out a paper form and send it directly to the IRS. Employers with more than 250 employees must file electronically. 

What should you do if you made a mistake on the form?

Mistakes happen to even the most seasoned employers. If you made a mistake on Form 1094-C and already filed it, you can file a correction form. 

To send a corrected copy, fill out a new form and put an X in the box next to “Corrected” at the top of the first page. Do not send anything else along with the corrected form. 

How long should you keep the form in your records?

Keep digital or paper copies of Form 1094-C (and 1095-C) in your records for at least three years.

Where can I find more information on Form 1094-C?

For more information on the form, you can review the IRS’s website or contact the IRS directly.

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