How to fix a late ACA filing, step by step.
The order matters. Accurate forms filed quickly beat perfect forms filed after the next penalty tier begins. Here are the steps, with the reasonable-cause and safe-harbor rules that can reduce the bill.
Start with the facts.
Confirm What Was Missed
Compare the forms filed against your full-time roster month by month. List employees with no form, a wrong form, or a form never furnished.
Build Accurate Forms
Rebuild each form from payroll hours and the offer record, so the codes on lines 14 and 16 tie to what you actually offered.
File and Furnish Now
File with the IRS and furnish employees as soon as the forms are right. The tier is set by when the correct return is filed.
Ways to limit the damage.
Reasonable Cause
Penalties may be waived if the failure was due to reasonable cause and not willful neglect, under Section 6724 and 26 CFR 301.6724-1.
The $100 Safe Harbor
A wrong dollar amount on line 15 generally need not be corrected if no single amount is off by more than $100, unless the recipient opts out.
Keep the Record
Write down why the forms were late and what you did to correct them.
Answer Any IRS Letter
Respond by the date on any penalty notice or Letter 226-J with corrected forms and a written statement.
Quick answers.
Short answers. This is general information, not legal or tax advice.
What Is the Cheapest Day to File?
The day you find the problem. The penalty tier is set by when the correct return is filed, not when you noticed.
Should We Wait for the IRS?
No. Waiting past 30 days or past August 1 raises the per-form penalty.
Can You Help?
Yes. We can help you with the filing and help keep you ERISA compliant. Send us what you have and we will tell you where you stand.
Where the rules and figures come from.
Each figure on this page comes from the source below. Amounts are indexed or updated over time, so confirm current figures before relying on them.
Instructions for Forms 1094-C and 1095-C
Due dates, extensions, the posted notice option, e-filing and the $100 safe harbor.
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.
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