Question: If we have Aggregated ALE Groups, do they need to file their own Authoritative Transmittal?
Answer: Yes, each individual company will file their own 1094/1095C and indicate that they are a member of an Aggregated Group (common ownership). Your Aggregated Group of companies may have a separate EIN for each or could have some of your companies that share an EIN, or could have a combination of some with their own EIN and some that share an EIN. For those that share an EIN, only one is the authoritative transmitter and you would designate so in their own entity filing. The Authoritative Company representing the companies with the shared EIN will have its own company 1095-C number on line 18 but line 20 will have the total number of 1095-C’s in the shared EIN group. The other non-authoritative will only have line 18 with the number of 1095-Cs for that company. All those that have a separate EIN as well as the Authoritative Company representing the group with the shared EIN will be marked as Authoritative on the Prerequisites window. Part IV will reflect only the authoritative companies that are in an Aggregated Group. Click Here for more information
One Authoritative Transmittal Required ALE Members that are subject to Section 6056 reporting may file more than one Form 1094-C to transmit Forms 1095-C.
- For example, an employer with two divisions may file Forms 1095-C for each division’s employees separately. On the Company setup in Configuration, just setup two companies with both having the same EIN.
- Each submission of Forms 1095-C must have a Form 1094-C transmittal. But, only one of the Forms 1094-C must be designated as the Authoritative Transmittal, which is a Form 1094-C on which the employer reports aggregate employer-level data for all full-time employees of the employer (e.g., including all employees of both divisions in the example above) in Parts II, III and IV if applicable.
- The Authoritative Transmittal is identified by checking the box on line 19 of the Form 1094-C.
- In contrast, only one Form 1095-C may be filed and furnished for each full-time employee of an employer (and each part-time employee who is enrolled in the employer’s self-insured plan). For example, an employer must combine the information on one Form 1095-C for an employee who works for two divisions of the employer during the year.
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Last Review: 5/17/2017 – Revision: 2.0
Applies To: ACA Reporting Requirements, ACA Compliance solution