ACA reporting is a year of records that gets filed in one week.
Forms 1094-C and 1095-C report what an employer offered each full-time employee, month by month. We can help you with the filing, and with the tracking that decides what the forms say.
Fifty full-time employees, counted the year before.
Applicable large employer status is measured on the prior calendar year, so a growing company is subject to the rules before it feels like a large employer.
Full-Time and Equivalents
Employees averaging 30 or more hours a week count in full, and part-time hours are converted into full-time equivalents. Fifty or more across the prior year makes the employer an applicable large employer.
Related Companies Count Together
Businesses under common ownership are combined for the count, even when each one runs its own payroll and its own plan.
Self-Funded Plans Report Coverage Too
A self-funded or level-funded plan reports who was covered each month, and that duty reaches employers below fifty as well.
The forms are only as good as the months behind them.
Every line on a 1095-C is a code, and every code is a claim about an offer, a cost and a status in a given month.
Variable-Hour Employees
Employees whose hours swing are measured over a look-back period, then treated as full-time or not for the stability period that follows. Set up once, it decides who gets an offer and what the form reports.
Affordability, Tested as You Go
The employee’s cost for the lowest-cost self-only plan is tested against the IRS percentage for the plan year, 9.96% for 2026, using a safe harbor, so a problem shows up at renewal rather than in an IRS letter.
Codes That Match What Happened
Offers, waivers, waiting periods and terminations are recorded as they happen, so the codes are built from records rather than rebuilt in February.
Filed and Furnished
We can help you with the filing. The forms are prepared, checked and filed electronically with the IRS, and furnished to employees by mail or through the notice-and-request option.
Two dates, and one of them changed.
Furnishing to Employees
31 January, with an automatic 30-day extension, so about 2 March. Employers may now post a clear notice that forms are available on request instead of mailing every one, as long as the notice stays up through 15 October and a requested form goes out within 30 days.
Filing with the IRS
28 February on paper or 31 March electronically. Electronic filing is required once an employer files 10 or more information returns of any kind in the year, and W-2s count toward that number.
States with Their Own Rules
California, New Jersey, Rhode Island, Massachusetts and the District of Columbia run their own coverage reporting, and the federal mailing relief does not change what they require.
What employers ask about ACA reporting.
We have 45 employees. Do we file 1094-C?
Not if you averaged fewer than fifty full-time and equivalent employees last year. If your plan is self-funded, you may still report coverage on the B forms.
What happens if the codes are wrong?
The IRS compares them with employees’ tax returns and marketplace subsidies, and a mismatch can lead to a penalty letter. The fix is accurate monthly records, not a better guess in February.
Can our payroll company handle this?
Some can file the forms, but the forms reflect benefits decisions payroll does not see: offers, waivers and eligibility. Someone has to own that side.
Do we still have to mail every 1095-C?
Not necessarily. Federal rules now allow a posted notice with forms furnished on request, but some states still require delivery.
When do we find out we are an applicable large employer?
At the start of the year, based on the year before, which is why a company that grew past fifty last year reports this year.
Is affordability based on family coverage?
No. It is tested on the employee’s cost for self-only coverage under the lowest-cost plan that provides minimum value.
Send us your renewal.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
An independent employee benefits consulting firm. We look at the entire benefits program — cost, plan performance, risk and administration.
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