Amwins Connect – December 2024 Question of the Month
Question
An Applicable Large Employer (ALE) has not filed 1094/1095-C information with the IRS for the past two years. The employer’s individuals enrolled in the medical group health plan have not received the 1095-C statement for the past two year. What should the employer do?
Answer
If the employer did not file for previous years, the technical answer is that they should correct this error by going back and preparing a Form 1094-C and Form 1095-Cs for all full-time employees for each year the employer was an ALE (applicable large employer).
The Form 1094-C and all Form 1095-Cs are submitted to the IRS and copies of the Form 1095-Cs must be distributed to the full-time employees.
However, even if this is done, it will likely trigger an automatic penalty letter from the IRS for late filings ($310 in 2024 multiplied by 2 for the failure to provide copies to the employees as well).
It is strongly recommended the employer report as required for the ‘missed years’ and going forward.
Other Resources
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