Form 1094-C: the transmittal that decides whether your 1095-Cs count

Form 1094-C is the transmittal an applicable large employer files with the set of Forms 1095-C it issues to employees. The 1095-C is the individual statement describing the coverage offered to one employee month by month; the 1094-C is the cover sheet describing the employer, the group it belongs to, and how many statements are being transmitted.

The asymmetry in attention is worth noticing. Employees receive the 1095-C and ask about it, so that is where employers concentrate. The 1094-C is where the employer certifies its own position — how many full-time employees it had each month, whether it offered coverage to enough of them, and which relief it is claiming — and that certification is the part with financial consequences.

What Form 1094-C carries

• Employer identification and contact details, and whether this is the authoritative transmittal for the employer.
• Aggregated group membership, where the employer is part of a controlled group — with the other members listed.
• Total number of 1095-C forms transmitted.
• A month-by-month grid: whether minimum essential coverage was offered, the full-time employee count and the total employee count for each month.
• Certifications of eligibility for the relief provisions the employer is relying on.
• Signature of the person authorised to make those certifications.

The monthly counts are the exposure

The month-by-month section is where a filing goes wrong quietly. The full-time employee count drives whether the employer met the coverage offer threshold in each month, and it is computed under rules about hours of service that do not match how most payroll systems categorise staff. Employers using a headcount of salaried staff, or a count as at a single date, produce numbers that look reasonable and are wrong — and the assessment that follows arrives long after the year has closed.

Only one 1094-C per employer identification number can be the authoritative transmittal. Employers filing in batches sometimes mark more than one, or none, and both produce correspondence. Decide which is authoritative before submitting anything.

Furnishing and filing are separate deadlines

The employee statements must be furnished to employees by one deadline and the return filed with the authorities by another, and the two are commonly confused. Electronic filing is required above a low return threshold that has been reduced in recent years, so employers who filed on paper a few years ago should check whether they still may. Corrections have their own process and their own form marking, and correcting a 1095-C issued to an employee also means reissuing their copy.

Keeping the evidence behind the counts

What an examination asks for is not the forms — those are already filed — but the basis for the monthly counts and the offers. Ettex Sheets holds the hours-of-service and full-time determination workbook per month, built from the same start dates as new hire reporting, Ettex Records keeps the filed transmittal, the employee statements and the offer evidence per year, and the payroll data underneath comes from the same source as form 941.

Plainly: this is records and spreadsheets, not benefits administration software, and none of it is tax or benefits advice. Applicable large employer status, hours-of-service measurement and relief eligibility are technical determinations for your benefits adviser.