The deadlines for filing the 2024 calendar year 1095-C and 1094-C forms are several months away, giving employers plenty of time to collaborate with the ACA vendors if they begin now. 

The 1095-C form is an informational return filed by applicable large employers (ALEs), those with 50 or more full time and equivalent employees. This form provides details pertaining to the employer's offer of health coverage, and the cost of the lowest plan tier available. The 1094-C form serves as a transmittal form (or a cover sheet). The 1094-C accompanies all copies of Form 1095-C that are submitted to the IRS. It also includes summary information about all of the employees covered by your plan, such as total number of employees, total number of full time employees, etc. 1095-C Forms are due to all full time employees by March 1, 2024. 

Employers with variable hour workforces must ensure they collect and analyze the 2024 measurement period data to identify any employees that are rendered ‘full time’ for the 2025 stability period. Likewise, any employees whose 2024 measurement data renders them part time will lose eligibility for 2025, and must receive offers of COBRA. This is the time to work with vendors on the complexity of variable hour tracking and proper 1095-C reporting for these individuals.

Employers filing 10 or more 1095-C must use the government’s AIR electronic filing system. AIR filings of the 1095-C and 1094-C are due by March 31, 2024. There is no longer a paper filing safe harbor for employers with fewer than 250 forms.