SmartFusion Modules -> Human Resources -> Insurance And Benefits -> Reports -> IRS Forms 1094-C and 1095-C

Overview

Applicable Large Employers (ALE) are required to file benefit offer and coverage data to the IRS to determine which entities owe fees for ACA compliance. The 1095-C form is the form distributed to employees (like W-2s) to inform employees of their coverage for filing income tax returns. The 1094-C form is the summary version that a customer will file with the IRS.

Unsupported Configurations

  • SmartFusion does not currently support filing 1094C/1095C reports for Aggregated ALE Groups.

Configuration and Setup Requirements

  • Employees are configured in payroll
  • Benefits are configured in Insurance & Benefits
  • Employees have benefits with health type attributes assigned in Insurance & Benefits
  • Employees have IRS benefit codes configured in the employee-benefit detail
  • Employees may have dependents defined on their employee-benefit detail
  • Employee benefits have effective start dates
  • Employee benefits without ends dates are still active benefits
  • Employee Dependents start and end dates are identical to employee benefit dated unless otherwise specified in dependent details

Terms and Concepts

Minimum Essential Coverage

Employees with health Benefits with IRS Benefit Offer Codes 1A, 1C,1E, 1F for each whole calendar month the benefit was effective, have minimum essential coverage. Codes 1B and 1D do not count since dependents are excluded by definition. 1G is for employees that are not 'Full Time'. 1H doesn't meet Minimum Essential Coverage.

What constitutes a Full-time Employee

Active employees with employee status of "Salaried" OR Active employees with employee type of "Daily, Hourly, or Leave of Absence" that worked an average of 130 hours or more for the calendar month, for each whole calendar month they are employed.

Employee must also have an Employment Status of "Full-Time". This is configured on the salary tab of the Payroll Enter/Edit Employee Master screen

How to check the Minimum Essential Coverage for each month if it is unchecked?

If work files have not yet been generated, a report will print with the verification report that will show a list of all full time employees without coverage by month. These employees' benefits will need to be reviewed and determined why they do not have coverage. Updating the benefits for these employees and ensuring they have minimum essential coverage as described above will ensure the checkbox is checked for each month.

If work files have been generated, there is an option to reset the work files. This option can be used to update the minimum essential coverage data if needed but keep in mind, it will reset all the ACA employee data as well.

Part I

Box 18 The total number of 1095-C Employees will include the number of employees that were active at any point during the reporting year.
Box 19 This is only checked If this is not an authoritative transmission. If it is not an authoritative transmission, then Part II, III, and IV will be left blank.

Part II

Box 20 Total number of Forms 1095-C filed by and/or on behalf of ALE Member.

Box 21 Is ALE Member a member of an Aggregated ALE Group?

Box 22

A. Qualifying Offer Method
D. 98% Offer Method

Part III

Box 23 Information for all 12 months can be populated when coverage is met for each month and counts are the same for each month. This is not an aggregate.

(a) Yes if minimum essential coverage was offered to 95% of full-time employees and their dependents for every month. When these conditions are met for all 12 months, the Yes box is checked on line 23 and Yes/No left blank on lines 24-35. If the conditions are not met for all 12 months, the No box is checked on line 23 and Yes/No left blank on lines 24-35. If the conditions are only met for some of the months, Yes/No box on line 23 is left blank and the boxes are checked Yes/No for each month on lines 24-35.
(b) Number of full-time employees for the ALE member when number is the same for every month. This is optional and will always be blank, instead showing counts for every month on lines 24-35.
(c) Number of active employees with an employee type of "Daily, Hourly, Leave of Absence, or Salaried" on the first day of each month when the number is the same for every month. This is optional and will always be blank, instead showing counts for every month on lines 24-35.
(d) Aggregated groups are not supported so this will be blank

Box 24-35 Contains information for each month. Only contains data if box 23 (a) has No checked.

(a) Yes if minimum essential coverage was offered to 95% of full-time employees and their dependents for the month. Otherwise, "No" will be checked.

The submission guidelines require the "First Day of the Payroll Period" NOT the "first payroll date" for 4980H relief in January 2015. SmartFusion does not store payroll period information anywhere, nor can it be implied accurately from payroll history. If 4980H relief applies to a user's employees in January, adjust the employee benefit start date to January 1st for accurate 1094-C totals.

(b) Number of full-time employees for the ALE member for the month. If box 22 D 98% Offer Method is selected, this will be left blank.
(c) Number of active employees with an employee type of "Daily, Hourly, Leave of Absence, or Salaried" on the first day of the month.
(d) Aggregated groups are not supported so this will be blank

Part IV

Since SmartFusion does not support for aggregated ALE Groups, this section will be left blank.

Reference Material

IRS Instructions: https://www.irs.gov/pub/irs-pdf/i109495c.pdf IRS 1094-C Sample: https://www.irs.gov/pub/irs-pdf/f1094c.pdf