Large Employers use the 6056 Reporting (Employer Mandate / “Pay or Play” /
MEC Double Check Reporting)
The “C” Forms 1094-C & 1095-C
Form 1094-C (IRS Transmittal Form)
Who has to file?
An Applicable Large Employer (“ALE”) that is subject to the Employer Mandate / “Pay or Play”
Due Date:
To the IRS on or before February 28 (March 31 if filed electronically) of the year immediately
following the calendar year for which the offer of coverage information is reported
Information Required
Four Parts:
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Applicable Large Employer Member
Employee & family Information
Employee – Monthly
Other ALE Members of Aggregated ALE Group
Before you start, you will need:
Employer Information:
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Names, addresses, etc.
Social Security Numbers**
Determination of whether employee was a full-time employee and for which months
For self-insured coverage, information about “covered individuals.”
Information for delivery (last known address / electronic delivery consent)
Information About Offers of Coverage Made:
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Was the coverage offered Adequate / of Minimum Value / 60% Actuarial Value?
Was the coverage offered Affordable (9.56%)?
Cost of employee’s share of lowest cost monthly premium for self only “Adequate”
coverage
Were offers made to spouses and dependents?
Was MEC offered to a sufficient percentage of Full-Time Employees, and their
dependents, in order to avoid penalties?
What is an “Offer of Coverage”?
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Must include dependent children (not spouses)
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Must provide an “effective opportunity” to enroll or decline at least once per year (may
be electronic)
Annual enrollment is not required if the employee is cost is zero (“0”) or at or below
Federal Poverty Line amount for a single individual.
Evergreen elections (with ability to opt out) are still permissible
An individual must be offered coverage for every day in the month to qualify as an offer
for the month.
A group will report no offer of coverage on line 14 if an employee is not enrolled for the
entire month (you will explain with a code on Line 16)
Form 1094-C Explained
Part 1:
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Name, address, and employer identification number (EIN) of the Employer
Name and telephone number of the person to contact who is responsible for answering
questions
Part 2:
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Total number of Forms 1095-C filed
Indication of whether this is an “authoritative transmittal.”
Certifications of eligibility – If the ALE uses one of the Offer Methods and/or one of the
forms of Transition Relief, it must check each applicable box
Part 3:
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MEC offer indicator (monthly breakdown, yes or no)
Full-time employee count
Total employee count
Aggregated group indicator
Section 4980H Transition Relief Indicator
Part 4:
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The employer must complete this section if it checks “Yes” on line 21 (Part 2)
If the employer was a member of a controlled/ aggregated group, enter the name(s) and
EIN of the other employer member(s) of the group.
Form 1094-C (IRS Transmittal Form)
INSTRUCTIONS (FINAL 2015):
http://www.irs.gov/pub/irs-pdf/i109495c.pdf
FORM (FINAL 2015):
http://www.irs.gov/pub/irs-pdf/f1094c.pdf
Form 1095-C Explained
Who has to file?
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Large employers that are subject to the Employer Mandate / Pay or Play
Part 3 (Covered Individuals) must be completed by an employer offering self-insured
health coverage for any individual who was an employee for one or more calendar
months of the year, whether full-time or not fulltime, and who enrolled in coverage.
Due Date:
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To the IRS - On or before February 28 (March 31 if filed electronically) of the year
immediately following the calendar year for which the offer of coverage information is
reported
An employer that files 250 or more Forms 1095-C must file electronically with the IRS
To the employee – On or before January 31 of the year following the calendar year for
which the offer of coverage information is reported
Form 1095-C
Information Required
Three Parts
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Part 1 – Employee
Part 2 – Employee Offer and Coverage
Part 3 – Covered Individuals
Part 1 – Employee
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Name, address and 9-digit social security number (SSN) of the employee.
Employer’s name, address and EIN.
Telephone number an individual seeking additional information may call to speak to a
person.
Check the box in column d if the individual was covered for at least one day per month
for all 12 months of the calendar year.
If the individual was not covered for all 12 months check the applicable box(es) for the
months in which the individual was covered for at least one day in column e.
Part 2 – Employee Offer and Coverage
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Line 14 – Offer of Coverage - For each calendar month, enter the applicable code from
Code Series 1.
Line 15 – Employee Share of Lowest Cost Monthly Premium for Self-Only Minimum
Value Coverage.
Line 16 – Applicable Section 4980H Safe Harbor – For each calendar month, enter the
applicable code from Code Series 2.
A Note on the Codes:
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These forms are tax fillings.
Douple will not give opinions or advice as to which codes groups should select for their
filing.
Groups should work with their own accountants and legal counsel for assistance in form
completion, especially when it comes to code selection.
Part 3 – Covered Individuals
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Name (column) and Social Security Number* (column b) of each covered individual.
Form 1095-C (Employee Form)
INSTRUCTIONS (2015 FINAL):
http://www.irs.gov/pub/irs-pdf/i109495c.pdf
FORM (2015 FINAL):
http://www.irs.gov/pub/irs-pdf/f1095c.pdf