Important Dates for Form 1094C

Form 1094-C is an essential document required by the Affordable Care Act (ACA) for employers to report health insurance coverage provided to employees. It’s used in conjunction with Form 1095-C to verify whether employers are offering minimum essential coverage to their employees. Understanding the critical dates associated with Form 1094-C is vital for compliance and to avoid penalties. This article will provide an in-depth look at the important dates you need to be aware of when handling Form 1094-C.

What is Form 1094-C?

Form 1094-C is known as the Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns. It acts as a cover sheet for Form 1095-C, summarizing the information provided in the individual employee forms. The IRS uses this form to determine if an employer is complying with the employer mandate under the ACA, which requires employers with 50 or more full-time employees (including full-time equivalent employees) to offer health insurance to their full-time workforce and their dependents.

Key Dates and Deadlines

January 31: Form 1095-C to Employees

Employers must provide Form 1095-C to employees by January 31 of the year following the coverage year. This form details the health insurance coverage offered to the employee, including whether the coverage meets the minimum essential coverage requirements. Providing this form on time is crucial as employees need it to complete their tax returns.

February 28: Paper Filing with the IRS

If an employer chooses to file Form 1094-C and the associated Forms 1095-C on paper, they must do so by February 28. This date is crucial for employers who prefer traditional mailing methods over electronic submission. However, it’s important to note that this method is typically available only to employers filing fewer than 250 forms.

March 31: Electronic Filing with the IRS

Employers who file 250 or more Forms 1095-C must file electronically, and the deadline for electronic filing is March 31. Even if an employer has fewer than 250 forms to file, they may choose to file electronically. Electronic filing is often preferred due to its efficiency and the extended deadline compared to paper filing.

Extensions

Employers can request an automatic 30-day extension for filing Forms 1094-C and 1095-C with the IRS by submitting Form 8809, Application for Extension of Time to File Information Returns. This extension must be requested before the original due date (February 28 for paper filers or March 31 for electronic filers). It’s important to note that this extension does not apply to the deadline for providing Form 1095-C to employees, which remains January 31.

Penalties for Late Filing

The IRS imposes penalties for late filing of Form 1094-C and associated Forms 1095-C. As of 2024, the penalties are as follows:

• $50 per form if filed within 30 days of the due date.
• $110 per form if filed more than 30 days late but before August 1.
• $280 per form if filed after August 1 or not filed at all.

Penalties can add up quickly, especially for larger employers who need to file multiple forms. Additionally, providing incorrect information or failing to furnish forms to employees by the January 31 deadline can also result in penalties.

Steps to Ensure Compliance

Accurate Record-Keeping

Ensure all employee health coverage information is accurately recorded throughout the year. This includes the type of coverage offered, the months it was delivered, and the employees and dependents covered.

Timely Distribution to Employees

Prepare and distribute Form 1095-C to employees by the January 31 deadline. Consider using electronic distribution methods to expedite the process and ensure delivery.

Choose Your Filing Method

Decide whether to file paper forms or electronically. If filing electronically, familiarize yourself with the IRS’s e-file system and ensure you have the necessary credentials.

Request Extensions if Needed

If you anticipate difficulties meeting the filing deadline, submit Form 8809 to request an extension. Remember, this only applies to filing with the IRS and not to distributing forms to employees.

Stay Updated on IRS Guidelines

The IRS may update its guidelines and requirements for Form 1094-C and Form 1095-C. Regularly check the IRS website or subscribe to updates to stay informed about any changes that may affect your filing process.

Conclusion

Form 1094-C is a crucial component of the ACA reporting requirements for employers. Adhering to the important dates associated with this form is essential for compliance and to avoid significant penalties. By providing Form 1095-C to employees by January 31, filing paper forms by February 28 or electronic forms by March 31, and requesting extensions when necessary, employers can ensure they meet their obligations under the ACA. Keeping accurate records and staying informed about IRS guidelines will further assist in a smooth and compliant filing process.

Employers should prioritize understanding and adhering to these deadlines to maintain compliance and support their employees in meeting their health coverage reporting requirements.