Applicable Large Employers (employers with 50 or more full-time equivalent employees) should have completed their employee shared responsibility reporting for the 2015 plan year. IRS 1095 forms should have been distributed to full-time employees and covered employees by March 31.
Now employers must turn their focus toward the Form 1094 requirements. Form 1094-B and Form 1094-C must be transmitted to the IRS along with information from the 1095 forms furnished to employees and covered individuals. Form 1094 is used to inform the IRS about offers of health coverage and enrollment in health coverage. The form itself contains summary information and the transmission includes the information from the employer’s 1095 forms.
Each separate employer in a controlled group must transmit its own Form 1094. While employers may transmit multiple Form 1094's, one form from each employer must be marked as the authoritative transmittal.
This year, Form 1094 must be transmitted to the IRS by June 30, 2016.
If an employer has 250 or more 1095 Forms, the 1094 transmission must be made electronically. For employers with fewer than 250 1095 Forms, the 1094 may be mailed to the IRS in a flat envelope.
BAS will be transmitting Form 1094 electronically for employers who engaged BAS for 2015 ACA data collection and form preparation services.