Instructions for IRS Form 1094-C, 1095-C

This document contains official instructions for IRS Form 1094-C, and IRS Form 1095-C. Both forms are released and collected by the Internal Revenue Service (IRS), a subdivision of the U.S. Department of the Treasury. An up-to-date fillable IRS Form 1094-C is available for download through this link. The latest available IRS Form 1095-C can be downloaded through this link.

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2020
Department of the Treasury
Internal Revenue Service
Instructions for Forms
1094-C and 1095-C
Section references are to the Internal Revenue Code unless
Information Reporting of Minimum Essential Coverage, see T.D.
otherwise noted.
9660, 2014-13 I.R.B. 842, at
www.irs.gov/irb/2014-13_IRB/
ar08.html. For the final regulations under section 4980H, Shared
Future Developments
Responsibility for Employers Regarding Health Coverage, see
T.D. 9655, 2014-9 I.R.B. 541, at
www.irs.gov/irb/2014-9_IRB/
For the latest information about developments related to Form
ar05.html. For answers to frequently asked questions regarding
1094-C, Transmittal of Employer-Provided Health Insurance
the employer shared responsibility provisions and related
Offer and Coverage Information Returns, and Form 1095-C,
information reporting requirements, visit IRS.gov.
Employer-Provided Health Insurance Offer and Coverage, and
instructions, such as legislation enacted after they were
For information related to filing Forms 1094-C and 1095-C
published, go to
IRS.gov/Form1094C
and IRS.gov/Form1095C.
electronically, visit IRS.gov/AIR. For FAQs specifically related to
completing Forms 1094-C and 1095-C, go to
IRS.gov/
What’s New
Affordable-Care-Act/Employers/Questions-and-Answers-about-
Information-Reporting-by-Employers-on-Form-1094-C-and-
Extension of due date for furnishing statements. The due
Form-1095-C.
date for furnishing Form 1095-C to individuals is extended from
January 31, 2021, to March 2, 2021. See
Notice 2020-76
and
For additional guidance and proposed regulatory changes
Extensions of time to furnish statements to
recipients.
relating to section 6055, including clarifications regarding the
reporting requirements for providers of minimum essential
Relief for failure to furnish statements to certain employ-
coverage and the requirement to solicit the TIN of each covered
ees enrolled in self-insured health plan. The IRS will not
individual for purposes of the reporting of health coverage
impose a penalty for failure to furnish Form 1095-C to any
information, see Proposed Regulations section 1.6055-1(h) and
employee enrolled in an ALE member’s self-insured health plan
Regulations section 301.6724-1.
who is not a full-time employee for any month of 2020 if certain
conditions are met. See
Notice 2020-76
and
Information
General Instructions for
reporting
penalties.
Extension of good faith relief for reporting and furnishing.
Forms 1094-C and 1095-C
The IRS will not impose a penalty for reporting incorrect or
See Definitions, later, for key terms used in these instructions.
incomplete information on the Forms 1095-C if you make a good
faith effort to comply with the information reporting requirements.
Purpose of Form
See
Notice 2020-76
and
Information reporting
penalties.
Employers with 50 or more full-time employees (including
Individual coverage health reimbursement arrangement
full-time equivalent employees) in the previous year use Forms
(HRA). For plan years beginning on or after January 1, 2020,
1094-C and 1095-C to report the information required under
employers may offer HRAs integrated with individual health
sections 6055 and 6056 about offers of health coverage and
insurance coverage or Medicare, subject to certain conditions
enrollment in health coverage for their employees. Form 1094-C
(individual coverage HRAs). On September 30, 2019, the IRS
must be used to report to the IRS summary information for each
and the Department of the Treasury issued proposed regulations
ALE Member (defined below) and to transmit Forms 1095-C to
clarifying the application of the employer shared responsibility
the IRS. Form 1095-C is used to report information about each
provisions in section 4980H to individual coverage HRAs and
employee to the IRS and to the employee. Forms 1094-C and
providing proposed safe harbors for the application of those
1095-C are used in determining whether an ALE Member owes
provisions to individual coverage HRAs. Generally, taxpayers
a payment under the employer shared responsibility provisions
are permitted to rely on the proposed regulations. Form 1095-C
under section 4980H. Form 1095-C is also used in determining
has been modified to add new codes for reporting offers of
the eligibility of employees for the premium tax credit.
individual coverage HRAs and new lines for reporting required
information. See the Instructions for
Part II
of Form 1095-C, later.
ALE Members that offer employer-sponsored, self-insured
Also see
Individual coverage HRA
and
Employee Required
coverage also use Form 1095-C to report information to the IRS
Contribution, later, for more information on how to calculate the
and to employees about individuals who have minimum
amount reported on line 15 for offers of individual coverage
essential coverage under the employer plan.
HRAs.
Who Must File
Plan start month. This is required for the 2020 Form 1095-C.
The Applicable Large Employer (ALE) must enter a two-digit
An ALE Member must file one or more Forms 1094-C (including
number.
a Form 1094-C designated as the Authoritative Transmittal,
whether or not filing multiple Forms 1094-C), and must file a
Additional Information
Form 1095-C for each employee who was a full-time employee
of the ALE Member for any month of the calendar year.
For information related to the Affordable Care Act, visit
IRS.gov/
Generally, the ALE Member is required to furnish a copy of the
ACA. For the final regulations under section 6056, Information
Form 1095-C (or a substitute form) to the employee.
Reporting by Applicable Large Employers on Health Insurance
Coverage Offered Under Employer-Sponsored Plans, see T.D.
An ALE Member is, generally, a single person or entity that is
9661, 2014-13 I.R.B. 855, at
www.irs.gov/irb/2014-13_IRB/
an Applicable Large Employer, or if applicable, each person or
ar09.html. For the final regulations under section 6055,
entity that is a member of an Aggregated ALE Group. An
Oct 09, 2020
Cat. No. 63018M
2020
Department of the Treasury
Internal Revenue Service
Instructions for Forms
1094-C and 1095-C
Section references are to the Internal Revenue Code unless
Information Reporting of Minimum Essential Coverage, see T.D.
otherwise noted.
9660, 2014-13 I.R.B. 842, at
www.irs.gov/irb/2014-13_IRB/
ar08.html. For the final regulations under section 4980H, Shared
Future Developments
Responsibility for Employers Regarding Health Coverage, see
T.D. 9655, 2014-9 I.R.B. 541, at
www.irs.gov/irb/2014-9_IRB/
For the latest information about developments related to Form
ar05.html. For answers to frequently asked questions regarding
1094-C, Transmittal of Employer-Provided Health Insurance
the employer shared responsibility provisions and related
Offer and Coverage Information Returns, and Form 1095-C,
information reporting requirements, visit IRS.gov.
Employer-Provided Health Insurance Offer and Coverage, and
instructions, such as legislation enacted after they were
For information related to filing Forms 1094-C and 1095-C
published, go to
IRS.gov/Form1094C
and IRS.gov/Form1095C.
electronically, visit IRS.gov/AIR. For FAQs specifically related to
completing Forms 1094-C and 1095-C, go to
IRS.gov/
What’s New
Affordable-Care-Act/Employers/Questions-and-Answers-about-
Information-Reporting-by-Employers-on-Form-1094-C-and-
Extension of due date for furnishing statements. The due
Form-1095-C.
date for furnishing Form 1095-C to individuals is extended from
January 31, 2021, to March 2, 2021. See
Notice 2020-76
and
For additional guidance and proposed regulatory changes
Extensions of time to furnish statements to
recipients.
relating to section 6055, including clarifications regarding the
reporting requirements for providers of minimum essential
Relief for failure to furnish statements to certain employ-
coverage and the requirement to solicit the TIN of each covered
ees enrolled in self-insured health plan. The IRS will not
individual for purposes of the reporting of health coverage
impose a penalty for failure to furnish Form 1095-C to any
information, see Proposed Regulations section 1.6055-1(h) and
employee enrolled in an ALE member’s self-insured health plan
Regulations section 301.6724-1.
who is not a full-time employee for any month of 2020 if certain
conditions are met. See
Notice 2020-76
and
Information
General Instructions for
reporting
penalties.
Extension of good faith relief for reporting and furnishing.
Forms 1094-C and 1095-C
The IRS will not impose a penalty for reporting incorrect or
See Definitions, later, for key terms used in these instructions.
incomplete information on the Forms 1095-C if you make a good
faith effort to comply with the information reporting requirements.
Purpose of Form
See
Notice 2020-76
and
Information reporting
penalties.
Employers with 50 or more full-time employees (including
Individual coverage health reimbursement arrangement
full-time equivalent employees) in the previous year use Forms
(HRA). For plan years beginning on or after January 1, 2020,
1094-C and 1095-C to report the information required under
employers may offer HRAs integrated with individual health
sections 6055 and 6056 about offers of health coverage and
insurance coverage or Medicare, subject to certain conditions
enrollment in health coverage for their employees. Form 1094-C
(individual coverage HRAs). On September 30, 2019, the IRS
must be used to report to the IRS summary information for each
and the Department of the Treasury issued proposed regulations
ALE Member (defined below) and to transmit Forms 1095-C to
clarifying the application of the employer shared responsibility
the IRS. Form 1095-C is used to report information about each
provisions in section 4980H to individual coverage HRAs and
employee to the IRS and to the employee. Forms 1094-C and
providing proposed safe harbors for the application of those
1095-C are used in determining whether an ALE Member owes
provisions to individual coverage HRAs. Generally, taxpayers
a payment under the employer shared responsibility provisions
are permitted to rely on the proposed regulations. Form 1095-C
under section 4980H. Form 1095-C is also used in determining
has been modified to add new codes for reporting offers of
the eligibility of employees for the premium tax credit.
individual coverage HRAs and new lines for reporting required
information. See the Instructions for
Part II
of Form 1095-C, later.
ALE Members that offer employer-sponsored, self-insured
Also see
Individual coverage HRA
and
Employee Required
coverage also use Form 1095-C to report information to the IRS
Contribution, later, for more information on how to calculate the
and to employees about individuals who have minimum
amount reported on line 15 for offers of individual coverage
essential coverage under the employer plan.
HRAs.
Who Must File
Plan start month. This is required for the 2020 Form 1095-C.
The Applicable Large Employer (ALE) must enter a two-digit
An ALE Member must file one or more Forms 1094-C (including
number.
a Form 1094-C designated as the Authoritative Transmittal,
whether or not filing multiple Forms 1094-C), and must file a
Additional Information
Form 1095-C for each employee who was a full-time employee
of the ALE Member for any month of the calendar year.
For information related to the Affordable Care Act, visit
IRS.gov/
Generally, the ALE Member is required to furnish a copy of the
ACA. For the final regulations under section 6056, Information
Form 1095-C (or a substitute form) to the employee.
Reporting by Applicable Large Employers on Health Insurance
Coverage Offered Under Employer-Sponsored Plans, see T.D.
An ALE Member is, generally, a single person or entity that is
9661, 2014-13 I.R.B. 855, at
www.irs.gov/irb/2014-13_IRB/
an Applicable Large Employer, or if applicable, each person or
ar09.html. For the final regulations under section 6055,
entity that is a member of an Aggregated ALE Group. An
Oct 09, 2020
Cat. No. 63018M
Applicable Large Employer, generally, is an employer with 50 or
1095-B to report information for employees who enrolled in the
more full-time employees (including full-time equivalent
employer-sponsored, self-insured health coverage.
employees) in the previous year. For purposes of determining if
Note. If an ALE Member is offering health coverage to
an employer or group of employers is an Applicable Large
employees other than under a self-insured plan, such as through
Employer, all ALE Members under common control (an
an insured health plan or a multiemployer health plan, the issuer
Aggregated ALE Group) are aggregated together. If the
of the insurance or the sponsor of the plan providing the
Aggregated ALE Group, taking into account the employees of all
coverage is required to furnish the information about their health
ALE Members in the group, employed on average 50 or more
coverage to any enrolled employees, and the ALE Member
full-time employees (including full-time equivalent employees)
should not complete Form 1095-C, Part III, for those employees.
on business days during the preceding calendar year, then the
Aggregated ALE Group is an Applicable Large Employer and
each separate employer within the group is an ALE Member.
Reporting of Enrollment Information
Each ALE Member is required to file Forms 1094-C and 1095-C
for Non-employees: Option
reporting offers of coverage to its full-time employees (even if the
To Use Forms 1094-B and 1095-B
ALE Member has fewer than 50 full-time employees of its own).
ALE Members that offer employer-sponsored, self-insured
For more information on which employers are subject to the
health coverage to non-employees who enroll in the coverage
employer shared responsibility provisions of section 4980H, see
may use Forms 1094-B and 1095-B, rather than Form 1095-C,
Employer
in the Definitions section of these instructions. For
Part III, to report coverage for those individuals and other family
more information on determining full-time employees, see
members. For this purpose, a non-employee includes, for
Full-Time Employee
in the Definitions section of these
example, a non-employee director, an individual who was a
instructions, which includes information on the treatment of new
retired employee during the entire year, or a non-employee
hires and employees in Limited Non-Assessment Periods.
COBRA beneficiary, including a former employee who
For purposes of reporting on Forms 1094-C and 1095-C,
terminated employment during a previous year.
an employee in a Limited Non-Assessment Period is not
TIP
considered a full-time employee during that period.
For information on reporting for non-employees enrolled in an
employer-sponsored, self-insured health plan using Forms
1094-B and 1095-B, see the instructions for those forms.
Reporting by Employers That
Sponsor Self-Insured Health Plans
For ALE Members that choose to use Form 1095-C to report
An employer that offers health coverage through a self-insured
coverage information for non-employees enrolled in an
health plan must report information about each individual
employer-sponsored, self-insured health plan, see the specific
enrolled in such coverage. For an employer that is an ALE
instructions for Form 1095-C,
Part III —Covered Individuals
Member, this information must be reported on Form 1095-C,
(Lines
18–30), later. Form 1095-C may be used only if the
Part III, for any employee who is enrolled in coverage (and any
individual identified on line 1 has an SSN.
spouse or dependent of that employee). See below for the
Substitute Statements to Recipients
option to file Form 1094-B and Form 1095-B, rather than Form
1094-C and Form 1095-C, to report coverage of certain
If you are not using the official IRS form to furnish statements to
nonemployees.
recipients, see Pub. 5223, General Rules and Specifications for
Affordable Care Act Substitute Forms 1095-A, 1094-B, 1095-B,
ALE Members that offer health coverage through an
1094-C, and 1095-C, which explains the requirements for format
employer-sponsored, self-insured health plan must complete
and content of substitute statements to recipients. You may
Form 1095-C, Parts I, II, and III, for any employee who enrolls in
develop them yourself or buy them from a private printer.
the health coverage, whether or not the employee is a full-time
Substitute statements furnished to recipients may be in portrait
employee for any month of the calendar year.
format; however, substitute returns filed with the IRS using paper
must be printed in landscape format.
For full-time employees enrolled in an ALE Member’s
self-insured coverage, including an employee who was a
Authoritative Transmittal for ALE
full-time employee for at least 1 month of the calendar year, the
Members Filing Multiple Forms 1094-C
ALE Member must complete Form 1095-C, Part II, according to
the generally applicable instructions, and should not enter code
A Form 1094-C must be filed when an ALE Member files one or
1G on line 14 for any month. For an employee enrolled in an ALE
more Forms 1095-C. An ALE Member may choose to file
Member’s self-insured coverage who is not a full-time employee
multiple Forms 1094-C, each accompanied by Forms 1095-C for
for any month of the calendar year (meaning that for all 12
a portion of its employees, provided that a Form 1095-C is filed
calendar months the employee was not a full-time employee), for
for each employee for whom the ALE Member is required to file.
Form 1095-C, Part II, the ALE Member must enter code 1G on
If an ALE Member files more than one Form 1094-C, one (and
line 14 in the “All 12 Months” column or in the separate monthly
only one) Form 1094-C filed by the ALE Member must be
boxes for all 12 calendar months, and the ALE Member need not
identified on line 19, Part I, as the Authoritative Transmittal, and,
complete Part II, lines 15 and 16.
on the Authoritative Transmittal, the ALE Member must report
certain aggregate data for all full-time employees and all
An individual coverage HRA is a self-insured group
employees, as applicable, of the ALE Member.
health plan and is therefore an eligible
TIP
Example 1. Employer A, an ALE Member, files a single
employer-sponsored plan. An individual is ineligible for a
Form 1094-C, attaching Forms 1095-C for each of its 100
premium tax credit (PTC) for a month if the individual is covered
full-time employees. This Form 1094-C should be identified as
by an individual coverage HRA or eligible for an individual
the Authoritative Transmittal on line 19, and the remainder of the
coverage HRA that is affordable.
form completed as indicated in the instructions for
line
19, later.
An employer that offers employer-sponsored, self-insured
Example 2. Employer B, an ALE Member, files two Forms
health coverage but is not an ALE Member should not file Forms
1094-C, one for each of its two operating divisions, Division X
1094-C and 1095-C, but should instead file Forms 1094-B and
and Division Y. (Division X and Division Y are units of the same
-2-
Instructions for Forms 1094-C and 1095-C (2020)
ALE Member, and thus both report under the same employer
Member. For any calendar month in which a full-time employee
identification number (EIN); they are not members of an
works for more than one ALE Member of an Aggregated ALE
Aggregated ALE Group.) Attached to one Form 1094-C are
Group, only one ALE Member is treated as the employer of that
Forms 1095-C for the 200 full-time employees of Division X, and
employee for reporting purposes (generally, the ALE Member for
attached to the other Form 1094-C are Forms 1095-C for the
whom the employee worked the greatest number of hours of
1,000 full-time employees of Division Y. One of these Forms
service), and only that ALE Member reports for that employee
1094-C should be identified as the Authoritative Transmittal on
for that calendar month. The other ALE Member is not required
line 19, and should include aggregate employer-level data for all
to report for that employee for that calendar month, unless the
1,200 full-time employees of Employer B as well as the total
other ALE Member is otherwise required to file Form 1095-C for
number of employees of Employer B, as applicable, as required
that employee because the individual was a full-time employee
in Parts II, III, and IV of Form 1094-C. The other Form 1094-C
of that ALE Member for a different month of the same calendar
should not be identified as the Authoritative Transmittal on
year. In this case, the individual may be treated as not employed
line 19, and should report on line 18 only the number of Forms
by that ALE Member for that calendar month. If under these
1095-C that are attached to that Form 1094-C, and should leave
rules, an ALE Member is not required to report for an employee
the remaining sections of the form blank, as indicated in the
for any month in the calendar year, the ALE Member is not
instructions for
line
19, later.
required to report for that full-time employee for that calendar
year. For a description of the rules related to determining which
Note. Each ALE Member must file its own Forms 1094-C and
ALE Member in an Aggregated ALE Group is treated as the
1095-C under its own separate EIN, even if the ALE Member is
employer for a month in this situation, see the definition of
part of an Aggregated ALE Group. No Authoritative Transmittal
Employee.
should be filed for an Aggregated ALE Group.
Example. Employer A and Employer B are separate ALE
Example 3. Assume that Employer A from Example 1 is a
Members that belong to the same Aggregated ALE Group. Both
member of the same Aggregated ALE Group as Employer B
Employer A and Employer B offer coverage through the AB
from Example 2. Accordingly, Employer A and Employer B are
health plan, which is an insured plan. In January and February,
separate ALE Members filing under separate EINs. Forms
Employee has 130 hours of service for Employer A and no hours
1094-C should be filed in the same manner indicated in
of service for Employer B. In March, Employee has 100 hours of
Examples 1 and 2. Employer A should include only information
service for Employer A and 30 hours of service for Employer B.
about employees of Employer A in its Authoritative Transmittal,
In April through December, Employee has 130 hours of service
and Employer B should include only information about
for Employer B and no hours of service for Employer A.
employees of Employer B in its Authoritative Transmittal. No
Employer A is the employer of Employee for filing purposes for
Authoritative Transmittal should be filed for the Aggregated ALE
January, February, and March. Employer A should file Form
Group reporting combined data for employees of both Employer
1095-C for Employee reporting offers of coverage using the
A and Employer B.
appropriate code on line 14 for January, February, and March,
should complete lines 15 and 16 per the instructions, and should
Similar rules apply for a Governmental Unit that has
include Employee in the count of total employees and full-time
delegated its reporting responsibilities for some of its employees
employees reported for those months on Form 1094-C. For the
to another Governmental Unit—see
Designated Governmental
months April through December, on Form 1095-C, Employer A
Entity (DGE)
in the Definitions section of these instructions for
should enter code 1H (no offer of coverage) on line 14, leave
more information. In the case of a Governmental Unit that has
line 15 blank, and enter code 2A (not an employee) on line 16
delegated its reporting responsibilities for some of its
(since Employee is treated as an employee of Employer B and
employees, the Governmental Unit must ensure that among the
not as an employee of Employer A in those months), and should
multiple Forms 1094-C filed by or on behalf of the Governmental
exclude Employee from the count of total employees and
Unit transmitting Forms 1095-C for the Governmental Unit’s
full-time employees reported for those months on Form 1094-C.
employees, one of the filed Forms 1094-C is designated as the
Authoritative Transmittal and reports aggregate employer-level
When To File
data for the Governmental Unit, as required in Parts II, III, and IV
You will meet the requirement to file Forms 1094-C and 1095-C
of Form 1094-C.
if the forms are properly addressed and mailed on or before the
Example. County is an Aggregated ALE Group made up of
due date. If the due date falls on a weekend or legal holiday,
the ALE Members School District, the Police District, and the
then the due date is the following business day. A business day
County General Office. The School District designates the state
is any day that is not a Saturday, Sunday, or legal holiday.
to report on behalf of the teachers and reports for itself for its
Generally, you must file Forms 1094-C and 1095-C by
remaining full-time employees. In this case, either the School
February 28 if filing on paper (or March 31 if filing electronically)
District or the state must file an Authoritative Transmittal
of the year following the calendar year to which the return
reporting aggregate employer-level data for the School District.
relates. For calendar year 2020, Forms 1094-C and 1095-C are
One Form 1095-C for Each
required to be filed by March 1, 2021, or March 31, 2021, if filing
electronically.
Employee of ALE Member
See
Furnishing Forms 1095-C to Employees
for information
For each full-time employee of an ALE Member, there must be
on when Form 1095-C must be furnished.
only one Form 1095-C filed for employment with that ALE
Member. For example, if an ALE Member separately reports for
Extensions
each of its two divisions, the ALE Member must combine the
offer and coverage information for any employee who worked at
You can get an automatic 30-day extension of time to file by
both divisions during the calendar year so that a single Form
completing Form 8809, Application for Extension of Time To File
1095-C is filed for the calendar year for that employee, which
Information Returns. The form may be submitted on paper, or
reports information for all 12 months of the calendar year from
through the FIRE System either as a fill-in form or an electronic
that ALE Member.
file. No signature or explanation is required for the extension.
In contrast, a full-time employee who works for more than one
However, you must file Form 8809 on or before the due date of
ALE Member that is a member of the same Aggregated ALE
the returns in order to get the 30-day extension. Under certain
Group must receive a separate Form 1095-C from each ALE
hardship conditions, you may apply for an additional 30-day
-3-
Instructions for Forms 1094-C and 1095-C (2020)
Electronic Filing
extension. See the Instructions for Form 8809 for more
information.
If you are required to file 250 or more
How to apply. As soon as you know that a 30-day extension of
information returns, you must file
time to file is needed, file Form 8809. See the instructions for
electronically. The 250-or-more
Form 8809. Mail or fax Form 8809 using the address and phone
requirement applies separately to each type of form filed and
number listed in the instructions. You can submit the extension
separately for original and corrected returns. For example, if you
request online through the FIRE System. You are encouraged to
must file 500 Forms 1095-B and 100 Forms 1095-C, you must
submit requests using the online fill-in form. See Pub. 1220, Part
file Forms 1095-B electronically, but you are not required to file
B, for more information on filing online or electronically.
Forms 1095-C electronically. If you have 150 Forms 1095-C to
correct, you may file the corrected returns on paper because
Where To File
they fall under the 250 threshold. However, if you have 300
Send all information returns filed on paper to the following:
Forms 1095-C to correct, they must be filed electronically. The
electronic filing requirement does not apply if you apply for and
receive a hardship waiver. The IRS encourages you to file
If your principal business,
electronically even though you are filing fewer than 250 returns.
office or agency, or legal
Use the following address:
residence, in the case of an
Waiver. To receive a waiver from the required filing of
individual, is located in:
information returns electronically, submit Form 8508. You are
encouraged to file Form 8508 at least 45 days before the due
date of the returns, but no later than the due date of the return.
Alabama, Arizona, Arkansas,
The IRS does not process waiver requests until January 1st of
Connecticut, Delaware, Florida,
the calendar year the returns are due. You cannot apply for a
Georgia, Kentucky, Louisiana,
waiver for more than 1 tax year at a time. If you need a waiver for
Maine, Massachusetts,
Department of the Treasury
more than 1 tax year, you must reapply at the appropriate time
Mississippi, New Hampshire,
Internal Revenue Service
each year. If a waiver for original returns is approved, any
New Jersey, New Mexico, New
Center
corrections for the same types of returns will be covered under
York, North Carolina, Ohio,
Austin, TX 73301
the waiver. However, if you submit original returns electronically
Pennsylvania, Rhode Island,
but you want to submit your corrections on paper, a waiver must
Texas, Vermont, Virginia,
be approved for the corrections if you must file 250 or more
West Virginia
corrections. If you receive an approved waiver, do not send a
copy of it to the service center where you file your paper returns.
Keep the waiver for your records only.
If you are required to file electronically but fail to do so, and
If your principal business,
you do not have an approved waiver, you may be subject to a
office or agency, or legal
penalty of $280 per return for failure to file electronically unless
Use the following address:
residence, in the case of an
you establish reasonable cause. However, you can file up to 250
individual, is located in:
returns on paper; those returns will not be subject to a penalty for
failure to file electronically. The penalty applies separately to
original returns and corrected returns.
Alaska, California, Colorado,
Pub. 5165, Guide for Electronically Filing Affordable Care Act
District of Columbia, Hawaii,
(ACA) Information Returns for Software Developers and
Idaho, Illinois, Indiana, Iowa,
Department of the Treasury
Transmitters, specifies the communication procedures,
Kansas, Maryland, Michigan,
Internal Revenue Service
transmission formats, business rules, validation procedures, and
Minnesota, Missouri, Montana,
Center
explains when a return will be accepted, accepted with errors, or
Nebraska, Nevada, North
rejected for returns filed electronically through the ACA
P.O. Box 219256
Dakota, Oklahoma, Oregon,
Information Return (AIR) system. To develop software for use
Kansas City, MO 64121-9256
South Carolina, South Dakota,
with the AIR system, software developers, transmitters, and
Tennessee, Utah, Washington,
issuers, including ALE Members filing their own Forms 1094-C
Wisconsin, Wyoming
and 1095-C, should use the guidelines provided in Pub. 5165
along with the Extensible Markup Language (XML) Schemas
published on IRS.gov.
If your legal residence or principal place of business or
Reminder. The formatting directions in these instructions (for
principal office or agency is outside the United States, file with
example, the directions to enter the 9–digit EIN, including the
the Department of the Treasury, Internal Revenue Service
dash on line 2 of Form 1094-C) are for the preparation of paper
Center, Austin, TX 73301.
returns. When filing forms electronically, the formatting set forth
in the XML Schemas and Business Rules published on IRS.gov
Shipping and mailing. If you are filing on paper, send the
must be followed rather than the formatting directions in these
forms to the IRS in a flat mailing (not folded), and do not
instructions. For more information regarding electronic filing, see
paperclip or staple the forms together. If you are sending many
Pubs. 5164 and 5165.
forms, you may send them in conveniently sized packages. On
each package, write your name, number the packages
Substitute Returns Filed With the IRS
consecutively, and place Form 1094-C in package number one.
If you are filing your returns on paper, see Pub. 5223 for
Postal regulations require forms and packages to be sent by
specifications for private printing of substitute information
First-Class Mail. Returns filed with the IRS must be printed in
landscape format.
returns. You may not request special consideration. Only forms
that conform to the official form and the specifications in Pub.
Keeping copies. Generally, keep copies of information returns
5223 are acceptable for filing with the IRS. Substitute returns
you filed with the IRS or have the ability to reconstruct the data
filed with the IRS must be printed in landscape format.
for at least 3 years, from the due date of the returns.
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Instructions for Forms 1094-C and 1095-C (2020)
VOID Box
If you fail to file correct information returns or fail to
furnish a correct recipient statement, you may be subject
!
Do not use this box on Form 1095-C.
to a penalty. However, you are not required to file
CAUTION
corrected returns for missing or incorrect TINs if you meet the
Corrected Forms 1094-C and 1095-C
reasonable cause criteria. For additional information, see Pub.
For information about filing corrections electronically,
1586, Reasonable Cause Regulations and Requirements for
Missing and Incorrect Name/TINs.
see section 7.1 of Pub. 5165.
TIP
See the charts for examples of errors and step-by-step
instructions for filing corrected returns.
Corrected Returns
TIP
A corrected return should be filed as soon as possible after an
error is discovered. File the corrected returns as follows.
Original Authoritative Transmittal Form 1094-C
Form 1094-C. If correcting information on the Authoritative
IF any of the following are
THEN ...
Transmittal (identified on Part I, line 19, as the Authoritative
incorrect ...
Transmittal, one (and only one) of which must be filed for each
ALE Member reporting aggregate employer-level data for all
full-time employees and employees of the ALE Member), file a
ALE Member or Designated
1. Prepare a new Authoritative
standalone, fully completed Form 1094-C, including the correct
Government Entity (Name and/or
Transmittal, Form 1094-C.
EIN)
information, and enter an “X” in the “CORRECTED” checkbox.
Do not file a return correcting information on a Form 1094-C that
2. Enter an “X” in the “CORRECTED”
checkbox at the top of the form.
is not the Authoritative Transmittal.
Total number of Forms 1095-C filed
Do not file any other documents (for example Form
by and/or on behalf of ALE Member
1095-C) with the corrected Authoritative Transmittal.
!
3. Submit the standalone corrected
Form 1094-C with the correct
CAUTION
Form 1095-C. If correcting information on a Form 1095-C
information present.
that was previously filed with the IRS, file a fully completed Form
Aggregated ALE Group Membership
1095-C, including the correct information and enter an “X” in the
“CORRECTED” checkbox. File a Form 1094-C (do not mark the
Certifications of Eligibility
“CORRECTED” checkbox on Form 1094-C) with corrected
Form(s) 1095-C. Furnish the employee a copy of the corrected
Minimum Essential Coverage Offer
Form 1095-C, unless the ALE Member was and continues to be
Indicator
eligible for and used the alternative method of furnishing under
the Qualifying Offer Method for that employee for that year’s
Section 4980H Full-Time Employee
Count for ALE Member
furnishing. For more information, see
Alternative method of
furnishing Form 1095-C to employees under the Qualifying Offer
Aggregated Group Indicator
Method.
Forms 1095-C filed with incorrect dollar amounts on line 15,
Other ALE Members of Aggregated
Employee Required Contribution, may fall under a safe harbor
ALE Group (Name and/or EIN)
for certain de minimis errors. The safe harbor generally applies if
no single amount in error differs from the correct amount by
more than $100. If the safe harbor applies, you will not have to
correct Form 1095-C to avoid penalties. However, if the recipient
Original Form 1095-C Submitted to IRS and Furnished to Employee
elects for the safe harbor not to apply, you may have to issue a
IF any of the following are
THEN ...
corrected Form 1095-C to avoid penalties. For more information,
incorrect ...
see Notice 2017-9, 2017-4 I.R.B. 542, at
www.irs.gov/irb/
2017-04
IRB/ar11.html.
Name, SSN, ALE Member EIN
1. Prepare a new Form 1095-C.
Note. Enter an “X” in the “CORRECTED” checkbox only when
Offer of Coverage (line 14)
2. Enter an “X” in the “CORRECTED”
correcting a Form 1095-C previously filed with the IRS. If you are
checkbox at the top of the form.
correcting a Form 1095-C that was previously furnished to a
recipient, but not filed with the IRS, write, type, or print
Employee Required Contribution
3. Submit corrected Forms 1095-C with
“CORRECTED” on the new Form 1095-C furnished to the
a nonauthoritative Form 1094-C
recipient.
transmittal to the IRS.
Correcting information affecting statement furnished to
Section 4980H Safe Harbor and
employee using an Alternative Furnishing Method under
Other Relief Codes (line 16)
the Qualifying Offer Method. If an ALE Member eligible to use
4. Furnish a corrected Form 1095-C to
the Qualifying Offer Method had furnished the employee an
the employee.
alternative statement, the ALE Member must furnish the
Covered Individuals Information
employee a corrected statement if it filed a corrected Form
1095-C correcting the ALE Member’s name, EIN, address, or
contact name and telephone number. If the ALE Member is no
longer eligible to use an alternative furnishing method for the
employee for whom it filed a corrected Form 1095-C, it must
furnish a Form 1095-C to the employee and advise the
employee that Form 1095-C replaces the statement it had
previously furnished.
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Instructions for Forms 1094-C and 1095-C (2020)