ACA Reporting Adviser

Welcome to MSEC’s weekly ACA FAQ on reporting. While details on how to complete IRS forms 1094 and 1095 (such as what codes to use on specific lines of the form) will not be covered, general questions on reporting requirements will be answered. For detailed information on form completion, contact your tax adviser, payroll company, or insurance carrier. If you have a general ACA reporting question, email it to aca@msec.org. The most commonly asked questions will be answered in this forum. In addition, the Health Care Reform Learning Zone, found on the MSEC website (msec.org), is a rich source of information about the Affordable Care Act (ACA).

I just discovered errors in an individual’s 1095-C. How do I make corrections?

You should file a corrected return as soon as possible after an error is discovered. Complete a new 1095-C, filling in all applicable lines, not just the correction information. Depending on what is being corrected, you may also need to do a corrected 1094-C.

In general, furnish the corrected statement to the individual and the IRS in the same manner as the original. If the original was provided electronically, send the correction electronically. If a paper copy was given, the correction should be a paper copy.

1095-C Corrections

If the form has been given to the individual but not yet sent to the IRS, write “CORRECTED” on the new form and furnish it to the recipient. Do not check the CORRECTED checkbox.

If the form has been submitted to the IRS and given to the individual, check the 1095-C’s CORRECTED checkbox to indicate to the IRS it is a corrected form. Provide the individual and the IRS with the corrected version. Also, send a non-authoritative 1094-C transmittal with the corrected form(s) to the IRS.

If you used an alternative statement method for 1095-Cs under the qualifying offer method, you may need to issue a corrected 1095-C instead of an alternative statement for the correction. See the correction chart in the IRS Form 1094-C/1095-C Instructions for details (link at end of article).

1094-C Corrections

Changes to the total number of 1095-C forms filed or the full-time employee count are examples of corrections that require a corrected 1094-C authoritative transmittal (defined below). See the IRS instructions for a complete list of corrections requiring a corrected 1094-C authoritative transmittal.

To correct the authoritative transmittal, file a standalone, fully completed 1094-C that includes the correct information and enter an “X” in the CORRECTED checkbox. Do not file any other documents (ex. 1095-Cs) with the corrected 1094-C. Do not file a corrected 1094-C that is not the authoritative transmittal.

ALE members may file separate 1094-C forms for different groups of employees. For example, a single corporation with two operating divisions may have each division file a separate 1094-C. One of these 1094-Cs must provide aggregate employer-level data for the ALE as a whole—this is the Authoritative Transmittal.

Electronic Corrections

Forms submitted electronically to the IRS must be corrected by electronic submittal. Corrections can only be made to previous submissions that have been Accepted or Accepted with Errors.

For information on electronic reporting corrections, see IRS Publication 5165, Section 7.

For general information on 1095-C and 1094-C corrections, see the IRS correction chart.