Do you know what is required for 1094 & 1095 reporting due Feb. 1st 2016?

If you are a C-level executive, HR Director, or business adviser to any of those roles, you had better know what the IRS is requiring for 1094-C and 1095-C reporting. This requirement is “sneaking” up on a lot of companies and applicable large employers will be required to start reporting this information in 2016 FOR THE 2015 CALENDAR YEAR!

IRS 2015 Instructions and Forms - 1094-C 1095-C : Click Here 

Form 1095-C General Facts

Who Files?

  • Applicable Large Employers with at least one full-time employee
  • If you have multiple entities under common ownership/control, each Applicable Large Employer member must provide a 1095-C for their employees.

How Many?

  • One form to every employee who was eligible for Minimum Essential Coverage (including serving a waiting period) at any time during the year.

How to File?

  • Paper forms to employees or electronically

When to File?

  • Employee on or before the last day of January
  • For 2015 reports, deadline is February 1, 2016, since January 31 is a Sunday

1094-C Reporting to IRS

  • Similar information as reported on 1095-C (accompanying copies or summary to IRS) with some changes.
  • Electronic filing required for 250+ 1095-C filers (first draft just released for the format and transmission).
  • Deadline to file:

o   last business day in February if sending in paper form

o   last business day in March if electronic

Q. Who Will Do the Work?

  •  Payroll providers?

o   Significant gaps between payroll and benefits

o   Cost is usually an add-on or offer incomplete services

  • Software companies?

o   No experience in benefits

o   Nothing ready to go or tested in new environment

A. Innovative Agencies…YES! We have a turnkey solution and answers to all of these questions.

  • Key Questions to Ask Vendors

o    Advice

o   Who will determine Line 14 & Line 16 codes on the 1095-C?

o   Can you assist with identifying employees who should receive 1095-C?

  • Are you willing to assume liability for the preparation and advice given with 1094/1095 reporting?
  • Communication

o   Will you print and mail 1095-C to those employees who are supposed to receive it?

  • Will you correct and issue amended 1095-C’s when errors are discovered? If so, what is the charge?
  • Can you resolve IRS questions directly or is that the employer’s responsibility?
  • How can I handle employee questions that will come next February?
  • Cost

o   Flat fee or per employee per month fee?

o   If PEPM - all employees or just those employees receiving 1095-C?

o   What are the set-up costs for this service?

  • Future

o   Will you give me a way to load this information in the future for 2016 reports and years after?


Please contact me with any questions. We are standing by ready to help. This service can be accessed as a standalone product, or can be part of a benefits admin package.  

Martin Gill

Partner, Lee Insurance

mgill@lee-ins.com