1. United States Affordable Care Act Year-End Processing Guide
  2. Preparation for AIR Year-End Reporting

Preparation for AIR Year-End Reporting

The following information helps you determine how to prepare for year-end reporting.

Deadline Information

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

Deadline Extensions and Waivers of Reporting Requirements

You can get an automatic 30-day extension of time to file by completing Form 8809 (Application for Extension of Time To File Information Returns).

To receive a waiver from the required filing of information returns electronically, submit Form 8508. You can request for Waiver From Filing Information Returns Electronically at least 45 days before the due date of the returns. You cannot apply for a waiver for more than one tax year at a time. If you need a waiver for more than one tax year, you must reapply at the appropriate time each year.

Government Regulations

JD Edwards World believes the IRS information that is included for your reference in this guide to be accurate as of the date of its publication; however, you should not rely on it as your sole source of information when filing reports or returns with the IRS. You should refer to the appropriate IRS publication or regulation for authoritative information and for guidance about filing requirements.

Note:

Before you can correctly adhere to IRS Information Returns reporting requirements, you must understand the IRS legislation and form instructions, the responsibilities, and the potential liabilities. Customers should be familiar with and understand ACA legislative requirements, and refer to their legal counsel or other advisors for guidance.

Supported Forms

The JD Edwards World system supports Form 1094-C Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns and Form 1095-C Employer-Provided Health Insurance Offer and Coverage applicable to ALEs. Forms 1094-B and 1095-B apply to insurance providers and are not supported by the JD Edwards World system.

Filing Paper Forms with the IRS

If you are filing your returns on paper, see Pub. 5223 for specifications about private printing of substitute information returns. You may not request special consideration. Only forms that conform to the official form and the specifications in Pub. 5223 are acceptable for filing with the IRS.

Note:

JD Edwards does not support paper filing of health coverage returns with the IRS, and therefore does not support a printed Form 1094-C or 1095-C for filing to the IRS. JD Edwards does support the printing of Form 1095-C for recipients.

Electronic Filing of ACA Information Returns

After the Form 1095-Cs have been printed and the 1094-C Build Employee Counts have been run, go to menu G08ACAEF. Select Work with 1094-Cs, select the unsubmitted 1094-Cs for inclusion in a transmission, and then request a transmission build. The transmission build creates the XML Form Data file and XML Manifest file. You can transmit these files to the IRS through the AIR System Web Portal. You must record the Receipt ID and submission date returned in the Web Portal on the transmission record. Once the file is processed, the IRS displays a transmission status. You must record the transmission status on the transmission and possibly the submission records.

Prerequisites

Before you file the ACA Information Returns electronically, complete the following tasks:

  • Register a responsible official and your contacts for a login with IRS E-Services.

  • Apply for and receive a Transmitter Control Code (TCC).

  • Pass a communication test with the AIR system and receive confirmation that your TCC has been placed in production status.

For more information, see Creating and Reviewing Submitted or Transmitted Form 1094-C

Registering for IRS e-Services

Employers who are the Transmitter (file ACA Information Returns electronically using the AIR system) must have at least one responsible official (and optionally, other contacts) who register personally with IRS e-Services. After making an application online, the registrant receives an IRS e-Services User ID and Password through the United States Postal Service (USPS) mail, which is required later to log into the AIR system.

Applying for a Transmitter Control Code

After receiving an IRS E-Services login, the responsible official must apply for a Transmitter Control Code (TCC). If you have multiple employers, one employer may act as the transmitter for all of your employers. When registering for a TCC, you must request the role of Transmitter and optionally the role of Issuer. Oracle JD Edwards World is registered with the role of Software Developer. The JD Edwards system is designed to use the AIR-UI Channel exclusively.

AIR System Communications Test

Once you have received your Transmitter Control Code, you must submit a one-time test transmission, called a communications test. This test verifies your ability to submit information returns with the AIR system. You utilize one of the test scenarios described in IRS publication 5164 - Test Package for Electronic Filers of Affordable Care Act (ACA) Information Returns (AIR). Your communications test must use your transmitter TCC and the Software Vendor ID for JD Edwards World, which is provided by Oracle JD Edwards. Your communications test must be Accepted or Accepted with Errors. Once the test transmission has been accepted, you call the IRS to verify the completion of the communications test and have them put your TCC in production status.

Correcting Accepted Form 1094-C and Form 1095-C

Corrections can only be made to previous submissions that have been Accepted or Accepted with Errors. Transmissions containing correction records must only contain corrections and should not include any Originals. The unique identifiers assigned by AIR allow corrections to the specific record(s), both transmittal records (Forms 1094) and information return records (Forms 1095). Corrections may be filed for the following form types:

  • Form 1094-C

  • Form 1095-C

Correcting Printed Form 1095-Cs Filed with the IRS

If making changes to paper Form 1095-Cs that were previously filed with the IRS, you will make changes to the 1095-C records in the JD Edwards system and reprint them. You must manually mark the CORRECTED box with an X.

Note:

JD Edwards does not support filing paper Forms 1094-C and 1095-C with the IRS.

Transmission or Submission Definitions and Limitations

An AIR system transmission using the UI Channel consists of one XML Form Data file and one XML Manifest file. Transmissions:

  • Consist of one or more submissions

  • Must not contain submissions of different types (must not have both Forms 1094-B or 1095-B and Forms 1094-C or 1095-C in the same transmission)

  • The Form Data file may not exceed 100 MB of uncompressed native XML.

  • A transmission must not mix Original and Corrected submissions.

Submissions:

  • Consist of one 1094-C and zero or more 1095-Cs.

  • The reported number of information returns on the 1094-C transmittal form must match the actual number of information returns.

  • If a transmission or submission is larger than 100 MB, the batch transmission build program automatically breaks up the transmission into two or more transmissions in the following way:

    • The first submission consists of the Forms 1094-C and as many Forms 1095-C as will fit within the 100 MB limit

    • The subsequent submission(s) will include Forms 1094-C, and as many associated Forms 1095- C as can be contained without exceeding the 100 MB size limit.

Submitting Records to the IRS

The transmission or submission process results in several different outcomes based on the data transmitted.

A submitted record requires formal correction if the Submission Status on the Submission record (SUIRSS in the file F08212) for the 1094-C is one of the following:

  • A: Accepted

  • E: Accepted with Errors

If submitted, but the status of the submission is blank, no change or delete is allowed because the transmission or submission is in progress.

IRS Resource List

To obtain the forms and for the latest information about developments related to Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, and instructions, such as legislation enacted after they were published, go to https://www.irs.gov/uac/about-form-1094-c and https://www.irs.gov/uac/about-form-1095-c.

You can also access Forms 1094-C and 1095-C instructions on the IRS website at https://www.irs.gov/pub/irs-pdf/i109495c.pdf. This document includes instructions for both forms as well as references to several other IRS resources and websites.