Thursday, May 26, 2016

ACA Form 1094-C Certification of Eligibility

Applicable Large Employers (ALEs) may be eligible for relief from certain requirements as they transition to payroll and benefits systems that meet Affordable Care Act standards.

In order to indicate to the IRS that they were eligible for this relief on their 2015 ACA return, ALEs will check a box indicating which Certification of Eligibility they qualified for on Line 22 of Form 1094-C. In this post, we’ve compiled a list of the four methods of relief found on Line 22 and how eligibility for them can be met.

Qualifying Offer Method (Box A)
A Qualifying Offer applies if you (the ALE) made a minimum value (MV) offer to at least one full-time employee for each month of the year they were full-time. Additionally, you would’ve needed to offer minimum essential coverage (MEC) to the employee’s spouse and dependent(s) that cost them no more than 9.5% of the federal poverty line (FPL).

Qualifying Offer Method Transition Relief (Box B)
This method of relief is available for the 2015 tax year only. An ALE must have made a qualifying offer (as described above) to 70% of their full-time employees for one or more months of the year. Filing Bonus: If you check Box A or B on your 1094-C, you can use a simplified, generic Form 1095-C instead of individual forms.

Section 4980H Transition Relief (Box C)
Section 4980H relief has two types, depending on just how LE of an ALE you are:
  • Option 1: ALEs with 50-99 FT employees are eligible if they didn’t reduce their workforce or their employees’ hours of work in order to meet ACA compliance requirements. They also can’t have reduced or eliminated coverage offered.
  • Option 2: ALEs with 100+ FT employees with this eligibility are subject to assessable penalty reduced by 80 employees instead of the standard 30.

98% Offer Method (Box D)
ALEs are eligible to check this box if they made an offer of affordable coverage (that meets MV qualifications) for every month of the year to at least 98% of the employees for whom they’re filing 1095-C forms. These can be enrolled full-time and part-time employees.

If you’re eligible for one of these relief methods, be sure to indicate so on your Form 1094-C. ExpressIRSForms can help prompt you to do this when you e-file your ACA Forms through our system, saving you from making any filing errors. For help getting started, you can call our support team in Rock Hill, SC at (704) 684-4751 Monday through Friday, 9:00 a.m. to 6:00 p.m. EDT. After hours, we offer assistance via our email,

Looking for something a little less hands-on? Check out ExpressACAForms, our full-service ACA e-filing option.

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