Part 1 of this series, the master guide, went through the ins and outs of the 1095-C forms required by the IRS. 1095-C forms are the most time-consuming part of this process.
The IRS outlines the more specific instructions for the 1094-C form here, but my main goal is to clear up some of the confusing language within their instructions. This process, however, is a lot more straightforward than the 1095-C forms!
The 1094-C form is kind of like a cover letter for the 1095-C forms. It’s the information the IRS needs about the employer itself, rather than each individual employee. It tells the IRS how many employee forms they’re getting, how big the company is, where they are, and info on how to contact the employer in case something gets massively screwed up.
Same as the 1095-C forms, the 1094-C form must be sent in to the IRS in paper (only for less than 250 employees) by the end of February, or by the end of March electronically. The 1094-C should accompany some, if not all, 1095-C forms, but the employer does not have to send them all at one time.
There must be one 1094-C that is identified as the Authoritative Transmittal. While this edition of the form does not have to be followed by all of the 1095-C forms, the AT must identify the total number of 1095-C forms that the IRS will be receiving from your company. For the sake of accuracy, it’s probably a better idea to send all 1095-C forms at once along with the AT. Your counts will be exact, and it all gets knocked out at once.
The Authoritative Transmittal is the only version of the 1094-C form that requires you to fill out all of parts II, III, and IV.
Should you need to send more than one 1094-C form, only one is the AT, and thus you do not have to complete section 9 of part II and beyond on any forms that are not the AT. You skip right to the signature.
Let us know if you have further questions, and check back for how to keep non-employee enrollees compliant.