ACA Information Returns Processing for 2024

Who Must File Forms 1094-C and 1095-C

ALEs (generally employers with 50 or more full-time employees (including full-time equivalent employees)) in the previous year, must file Form 1095-C for each full-time employee for any month of the calender year. Generally, the employer is required to furnish a copy of the Form 1095-C (or a substitute form) to the employee.

Each employer has their own reporting obligation related to the health coverage that they offered (or did not offer) to each of their full-time employees. Generally, an employer is subject to employer shared responsibility provisions under section 4980H when they have 50 or more full-time employees, including full-time equivalent employees, during the prior calendar year.

An employer that offers health coverage through an employer-sponsored self-insured health plan must complete Form 1095-C, Parts I, II, and III, for any employee who enrolls in the health coverage, whether or not the employee is a full-time employee for any month of the calendar year. If the employee who enrolled in self-insured coverage is a full-time employee for any month of the calendar year, the employer must complete Part II (in addition to Parts I and III). If the employee who enrolled is not a full-time employee for any months of the calendar year (which means that for all 12 calendar months the employee was not a full-time employee), the employer must complete Form 1095-C, Parts I and III and on Part II, must enter code 1G on line 14 in the All 12 Months column or in each separate monthly box (the employer need not complete Part II, lines 15 16 and 17 in this case).

If an employer is offering health coverage to employees other than under a self-insured plan, such as through an insured health plan or a multi-employer health plan, the issuer of the insurance or the sponsor of the plan providing the coverage is required to furnish the information about their health coverage to any enrolled employees, and the employer should not complete Form 1095-C, Part III, for those employees.

An employer that offers employer-sponsored self-insured health coverage but is not an ALE subject to the employer shared responsibility provisions under section 4980H, should not file Forms 1094-C and 1095-C.

You should submit Form 1095-C for:

Employees who were full-time for any month of the year
Employees who enrolled in self-insured coverage, regardless of their full-time status
COBRA participants and retirees to cover under a health coverage plan

Authoritative Transmittal for Employers Filing Multiple Forms 1094-C

Each original submission to the IRS contains one Form 1094-C and a number of Form 1095-Cs. An employer may create as many submissions as required. If an employer creates multiple submissions (files multiple Forms 1094-C and accompanying Form 1095-Cs), one submission must contain an Authoritative Transmittal 1094-C, containing the summary information for the employer.

Note:

A Form 1094-C designated as an Authoritative Transmittal can be identified on Line19, Part I of Form 1094-C.

When to File Forms 1094-C and 1095-C

You need to meet the requirements to file Forms 1094-C and 1095-C, and verify if the forms are properly addressed and mailed on or before the due date. If the regular due date falls on a Saturday, a Sunday, or a legal holiday, file by the next business day. A business day is any day that is not a Saturday, a Sunday, or a legal holiday.

You must distribute Form 1095-C to employees by January 31 of the year following the calendar year to which the return relates. JD Edwards currently supports only paper distributions to employees.

Generally, you must file Forms 1094-C and 1095-C with the IRS by February 28 if filing on paper (or March 31 if filing electronically) of the year following the calendar year to which the return relates. For calendar year 2024, Forms 1094-C and 1095-C are required to be filed with the IRS by February 28, 2025, if filing on paper, or March 31, 2025, if filing electronically.

If you are required to file 250 or more information returns, you must file electronically. The electronic filing requirement does not apply if you apply for and receive a hardship waiver. The IRS encourages you to file electronically even if you are filing fewer than 250 returns.

Note:

JD Edwards does not support paper filing of information returns to the IRS.

How to File Forms 1094-C and 1095-C

This guide describes how to electronically file Forms 1094-C and 1095-C with the IRS. Once the workfiles have been built and reviewed, you will produce paper Form 1095-Cs for sending to recipients. Then, prepare the XML files to transmit to the IRS through the ACA Information Returns (AIR) System web portal.

The Internal Revenue Service (IRS) strongly encourages the quality review of data before filing, to prevent erroneous notices from being mailed to statement recipients (or others for whom information is being reported).

Furnishing Paper Form 1095-Cs to Recipients

You should meet the requirement to furnish Form 1095-C to an employee if the form is properly addressed and mailed on or before the due date. If the regular due date falls on a Saturday, a Sunday, or a legal holiday, file by the next business day. A business day is any day that is not a Saturday, a Sunday, or a legal holiday.

Generally, an employer must furnish a Form 1095-C to each of its full-time employees by January 31 of the year following the year to which the Form 1095-C relates.

Correcting Paper Form 1095-Cs Furnished to Recipients

If you want to make corrections to the Form 1095-Cs that were distributed to employees or other recipients before they are submitted to the IRS, you may make changes to the original Form 1095-C records in the system and reprint the forms for distribution to employees. Do not mark the CORRECTED box, instead, write the word Corrected on the paper form. These records will still be considered original when submitted to the IRS.

Transmitting Forms 1094-C and 1095-C to the IRS

Affordable Care Act Information Returns (Forms 1094-C and 1095-C) must be filed using the Affordable Care Act Information Returns System (AIR). The transmission of returns must be in the defined XML format within the 100 MB limit.

Ensure that the registration, TCC application, and pre-filing activities are complete. To use the AIR system, you must apply for and receive a Transmitter Control Code (TCC), and pass a one-time communication test. The TCC application is available on https://www.irs.gov/. See the IRS publications 5164, 5165, and the IRS AIR program for more information.