The draft instructions and forms (1094-C and 1095-C) have been issued for assisting applicable large employers (50+ FTE) with reporting in the beginning of 2016. The final versions of the instructions and forms will be issued at a later date. If you will not be utilizing your payroll vendor to complete this reporting requirement on your behalf, we encourage employers to review the below proactive action items:

1. Ensure the data needed to complete the forms will be readily available when you need it. Data such as:

  • 1094-C
    • Employer’s name, address, and EIN
    • Name and phone number for a contact person
    • Number of full-time employees (by calendar month)
    • Number of total employees (by calendar month)
  • 1095-C (only needed for full time and full time equivalent employees)
    • Employee name, address, and SSN
    • Employment status (by calendar month)
    • If coverage was available/offered (by calendar month)
    • The employee’s enrollment status (by calendar month)
    • The monthly premium contribution for self-only coverage on the lowest applicable plan offered (by calendar month)
    • The affordability safe harbor method

2. If this data is being saved in a current database, will you be able to easily pull reports to get the data in a usable format?

  • If yes, that is great and will make it much easier to move forward on your own or with a third party vendor.
  • If no, we suggest you talk with your vendor to ensure they will be able to assist you with obtaining this data from their system OR start tracking this data outside the system.
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