Employer Reporting Tip - ACA Forms 1094 and 1095 Reporting in Early 2024

Employer Reporting Tip - ACA Forms 1094 and 1095 Reporting in Early 2024

Q: Which employers are required to prepare and file Forms 1094 and 1095 early in 2024?

A: All applicable large employers (ALEs) must complete one Form 1094-C and a Form 1095-C for each employee who was full-time for at least one month during 2023. ALE status for 2023 is generally determined based on the employer’s average full-time equivalents (FTEs) during the 2022 calendar year. In addition, employers who offered self-funded or level-funded medical coverage during 2023 must report for all individuals who were enrolled in the employer’s plan at any time during 2023. Small employers (<50 FTEs) report such coverage information using Form 1094-B and Form 1095-Bs. ALEs generally report coverage information in Part III of Form 1095-C.

NOTE: If the employer covered individuals residing in CA, MA, NJ, RI or DC, state level coverage reporting may be required as well.