Q: We have a parent company with 9 sister companies. We were initially advised to file all 1,200 1095-C forms under the parent company, but now have been instructed to file the 1094-C forms for all companies even though sister companies are showing a total of zero 1095-C forms filed. Is this correct?
A: According to the IRS instructions: There must be only one Authoritative Transmittal filed for each employer. If this is the only Form 1094-C being filed for the employer, this Form 1094-C must report aggregate employer-level data for the employer and be identified on line 19 as the Authoritative Transmittal. If multiple Forms 1094-C are being filed for an employer so that Forms 1095-C for all full-time employees of the employer are not attached to a single Form 1094-C transmittal (because Forms 1095-C for some full-time employees of the employer are being transmitted separately), one of the Forms 1094-C must report aggregate employer-level data for the employer and be identified on line 19 as the Authoritative Transmittal. Learn more here.
Q: How do we inform the IRS that some of the 1094-C forms we are responsible to report on are for retired employees?
A: According to the IRS instructions: A retiree (meaning an individual who was not an employee during the applicable period) is not a full-time employee. However, if the retiree was a full-time employee for any month of the calendar year (for example, before retiring mid-year), the employer must complete information in Part II of Form 1095-C for all twelve months of the calendar year, using the appropriate codes. Q: Do you send in a copy of each 1095-C with the 1094-C to the IRS? A: Yes. The 1094-C acts as a cover sheet and should be sent with copies of all applicable 1095-C forms.
Q: If we filed on paper, how would we know if errors occurred?
A: The IRS will notify you once they have received your paper filing and determine if there are errors.
Questions on 1094-C and 1095-C transmission issues
Q: After transmitting 1094-C and 1095-C forms to the IRS for reporting, we are getting TIN Validation Errors. What can we do after we have verified the names and SSNs in our records are correct?
A: If you have verified with an I-9 form, simply submit to the IRS. You may receive an error but the IRS has informed us that this is acceptable.
Q: We have filed with the IRS and continue to receive a rejected response due to “EIN invalid”. We have verified the EIN and name according to what we have on our W-2. The IRS has not been helpful. A: Be sure that you are not using a “paymaster” EIN. In some cases, employers use this EIN on their W-2 forms, but it is not the EIN number that the IRS will be matching to for reporting purposes.
Q: If an apostrophe is not allowed for a last name, how do you handle the name? Do you leave a space or run it all together? A: Spaces are not permitted. We suggest running the name together – for example, O’Brien would read Obrien.
Q: Should an address be updated on the 1095 form for the transmittal? If an employee has changed their address after the 1095-C form was sent, should we update the address for the transmittal?
A: Here is a link to the Instructions for the 1094-C and 1095-C forms. Scroll down to the “TIP” table to see instructions on corrections.
Q: We have been trying to electronically submit the 1094C and 1095C’s for reporting to the IRS. We have the TCC code, we passed the test and are now in production. We continue to receive errors.
A: We suggest that you check this link for information on the IRS website error codes. See Appendix A: AIR TY 2015 Error Code Library. You can submit questions to airmailbox@irs.gov regarding electronic filing of Forms 1094-B, 1094-C, 1095-B and 1095-C.
Q: We have passed the testing phase for electronically filing the 1094-C/1095-C but when filing in production we get errors regarding the “schematic”—what should we do?
A: We recommend that you check this link for information on error codes. See Appendix A: AIR TY 2015 Error Code Library. You can submit questions to airmailbox@irs.gov regarding electronic filing of Forms 1094-B, 1094-C, 1095-B and 1095-C.
Q: Since apostrophes are an issue in names, what about hyphenated last names?
A: Hyphenated names are fine—the hyphen is permitted for reporting to the IRS.
Q: Can you explain when we can use a Date of Birth (DOB) instead of a Social Security Number (SSN)?
A: The IRS expects you to try to get an accurate SSN three times. If you are unable to get it after those three attempts, you can use a DOB.
Q: What do you recommend when we received an IRS rejection on our 1094-C/1095-Cs and we just learned that an employee submitted two different SSNs to us? Should we submit the new one received after filing?
A: You can correct the SSN and re-transmit to the IRS.
Need help? Benefitfocus provides rigorous checks to help identify data errors as well as IRS transmission errors. We provide reports that show which errors are critical to rejecting an IRS submission and which errors might cause compliance issues. Get more information on our ACA compliance solutions here.
The information provided does not, and is not intended to, constitute legal advice; instead, all information and content herein is provided for general informational purposes only and may not constitute the most up-to-date legal or other information.
