Form 1094-C and Form 1095-C/B

Large Companies’ healthcare options must comply with the Affordable Care Act (ACA). Applicable large employers (ALEs) with 50 or more full-time employees use Form 1094-C and Form 1095-C to show that their health coverage was in compliance.

Form 1094-C is used to report to the IRS summary information for each employer and to transmit Form 1095-C to the IRS. Form 1095-C is used to report information about each employee, while Form 1095-B is used to provide those employees with their own report of their coverage.

The information reported on Form 1094-C and Form 1095-C is used to determine if and how much an employer may be liable for. The IRS also uses Form 1095-C to determine an employee’s premium tax credit eligibility. Fully insured or small group self-funded plans must provide 1095-B’s to covered individuals, however, large group self-funded plans have all of this information included in their 1095-C’s.

Form 1094-C is unchanged from last year, however, Form 1095-C now includes codes relating to a new type of health reimbursement account (HRA), an individual coverage HRA (ICHRA).

ICHRAs, created by the IRS in mid-2019, allow employers to fund ACA-compliant health coverage for eligible employees by predetermining a dollar amount to contribute each year. The addition of these codes allow employees to view how their ICHRA was determined.


ACA Requirement Deadlines

February 28: Paper filing with IRS

March 2: 1095 forms delivered to employees 

March 31: Electronic filing with IRS 


New Jersey’s Requirements

New Jersey requires that a 1095 form be sent to each primary enrollee who was a New Jersey resident in 2020, as opposed to having it available upon their request. In order for the 1095-C form to meet filing requirements, Part III must be fully completed. Unlike other states, employers do not have to provide separate 1095 forms to spouses or dependents.

For additional details about reporting requirements, visit the IRS’s questions and answers page or call BMPG!