Trending ACA Reporting Questions on our Community

Trending ACA Reporting Questions

We’re getting down to the wire! Deadlines for filing forms 1094-C and 1095-C are fast approaching, and the clients of our ACA Management Solutions have been making good use the Equifax ACA Community site to get the last minute information they’re after.

Curious what the top trending ACA reporting questions are on our ACA Community KnowledgeBase? Here’s a list of the most accessed articles and questions along with brief answers to point you in the right direction.

Here are the top trending ACA reporting questions at Equifax ACA Community:

Q: Does the IRS have any resources available for Forms 1094-C and 1095-C?

A: Yes, quite a few. Here are some handy links to IRS resources:


Q: How many FEINs should show on Part IV of the 1094-?

A: Up to 30 of the other Aggregated ALE Group members (not including the reporting ALE Member) should show on Part IV of the 1094-C. If there are more than 30 members of the Aggregated ALE Group (not including the reporting ALE Member), enter the 30 with the highest monthly average number of full-time employees.


Q: What’s changed from 2015 on the 1094-C?

A: Here are noteworthy changes:

  • Form Revisions: On Form 1094-C, line 22, box B is designated “Reserved.” The Qualifying Offer Method Transition Relief is not applicable for 2016. In Part III, column (b), “Section 4980H” was inserted before “Full-Time Employee Count for ALE Member” to remind filers that the section 4980H definition of “full-time employee” applies for purposes of this column, not any other definition that an ALE Member may use for other purposes. On Form 1095-C, the language “Do not attach to your tax return. Keep for your records” was inserted under the title of the form to inform the recipient that Form 1095-C should not be submitted with the return. On line 15, the heading was revised to read “Employee Required Contribution (see instructions).” Other minor clarifying changes were made to both forms.
  • Transition Relief: Several forms of transition relief were available to employers for 2015 under sections 4980H and 6056, but only limited transition relief continues to apply in 2016. References to transition relief that applied only in calendar year 2015 have been removed. Descriptions of the remaining forms of transition relief have been amended to clarify for which months in 2016 the transition relief applies.
  • For more information, visit the IRS Instructions for Forms 1094-C here.


Q: What are the IRS business rules for Tax Year 2016 for the 1095-C?

A: These can be downloaded directly from the IRS on this page.


Q: What are the IRS business rules for Tax Year 2016 for the 1094-C?

A: These can be downloaded directly from the IRS on this page.


Q: When should I submit my 1094-C form (Tax Year 2016) for transmittal to the IRS?

A: The IRS deadline is March 31, 2017. As soon as your 1094-C has been reviewed and confirmed as accurate, it can be sent/transmitted to the IRS. However, you should check with your individual compliance or technology vendor to see if they have a submission deadline prior to the IRS deadline. For example, Equifax requires submissions be received on or before March 24, 2017 to ensure on-time transmittal to the IRS.