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Coding and Filing Your 1095-Cs

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This post is for Applicable Large Employers (ALEs) required to comply with the Affordable Care Act. We hope you find it useful.

According to a recent report Lattice, HR professionals are dealing with more responsibilities than ever due to the pandemic.

HR teams are responsible for setting remote work policies, and they are dealing with administrative duties caused by the “Great Resignation,” a widespread trend of employees resigning from their jobs and applying elsewhere.

In addition to managing talent acquisition, HR professionals may be spearheading employee engagement, managing in-house training, diversity and inclusion initiatives, as well as administering performance reviews.

And, in the midst of an array of varied responsibilities, many HR professionals are still taxed with the burdensome duty of ACA compliance management for their companies.

Managing ACA-related employee data and accurately coding and filing forms 1095-C can be complicated. If you are manually tracking data or underwhelmed with your current ACA software or solution, we can help.

Our IRS-approved ACA software or ACA Full Service option can help you streamline filing, avoid penalties, and ease the burden of managing compliance year-round.

Our friendly experts can answer any ACA-related questions you may have, and we are IRS-approved to optionally file on your behalf.

Form 1095-C

According to the IRS, form 1095-C “is filed and furnished to any employee of an Applicable Large Employers (ALE) member who is a full-time employee for one or more months of the calendar. ALE members must report that information for all twelve months of the calendar year for each employee.”

Applicable Large Employers (ALEs) are companies with 50+ full-time employees (or full-time equivalents).

An ALE must file a 1095-C with the IRS for each of its full-time employees, who must also be issued a copy of the form. Some states such as CA, NJ, and MA also require state-level ACA reporting.

Form 1095-C requires basic employee information including name, address, date of birth, SSN, and this form also includes fields for the type of coverage received and cost.


Companies with 250+ 1095-Cs must file electronically, and paper filing is an option for smaller companies. Each as a separate deadline, and generally you must file Forms 1094-C and 1095-C by February 28 if filing on paper or March 31 if filing electronically (provided there are no extensions on the due dates).

1094-Cs provide employer information and are filed with the 1095-Cs. The 1094-C form also provides the number of 1095-Cs being submitted to the IRS.

If finalized, a new IRS proposal will reduce the 250-return threshold for electronic filing to 100 for returns due in 2022 – and this may drop to 10 for returns filed in 2023 or later.

Failure to file, furnish, or late filing of 1095-Cs can result in ACA penalties.

How do you code the 1095-C form?

Accurately coding 1095-Cs is important as the IRS has been ramping up enforcement of ACA non-compliance:

  • It’s important to ensure you offer Minimum Essential Coverage to at least 95% of your full-time employees (and their dependents) that meet the Minimum Value criteria required by the IRS.
  • And, the coverage for the full-time employee must be considered affordable based on IRS criteria.

Lines 14, 15, and 16 make up Part 2 of the 1095-C and provide details of an employer’s offer of coverage to a full-time employee. Knowing how to correctly complete this section is imperative for Affordable Care Act compliance and avoiding penalties. Here are some tips for coding lines 14-16 of the 1095-C from our ACA compliance specialist.

To learn more about how Passport Software’s ACA software and services can help ease the burden of compliance call 800-969-7900. Or, contact us – we are here to help.

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