When can I start filing forms 1095-C for my employees?

Updated March 12, 2019

While this is a pretty straightforward question, the answer is not quite as simple. As a general rule, you can begin filing forms 1095-C once the IRS has released the final version of the form for the filing season. The IRS recently released final copies of the 1094-C and 1095-C series forms (e.g. 1094-C and 1095-C) for tax year 2018. It has been commonplace for these forms to be released late in the 4th quarter of the calendar year. In the past, the IRS has been much quicker to release other year-end forms, like form W-2, than the ACA information returns.

2018 Form 1094 and Form 1095-C Instructions: https://www.irs.gov/pub/irs-pdf/i109495c.pdf

2018 Form 1095-C: https://www.irs.gov/pub/irs-pdf/f1095c.pdf 

2018 Form 1094-C: https://www.irs.gov/pub/irs-pdf/f1094c.pdf

Now, the IRS released the final version of the forms, your software vendor has to finalize the copy of the forms in their respective systems and then release them for use by clients. Typically, the IRS provides an advanced “draft” copy of the forms earlier in the year (as they have done already this year) so as to allow ACA reporting vendors time to begin addressing the changes required for the new year.  The ability to print the new forms may also require that the solution be able to create the data for the forms using the final instructions and other IRS provided documentation. This is often much more time consuming than merely changing a printed report within the solution. For example, the Integrity ACA “Year-End” process is updated on an annual basis to ensure that the ACA form 1095-C is properly and accurately generated based on any changes released by the IRS.

In addition to the form and processing changes themselves, many software companies also support electronic filing of the forms that are supported by the system. As such, many software companies will incorporate form updates with the necessary electronic filing changes in a single release. Others, may break these up into separate releases to their clients. This is easier done in a SaaS offering, like the Integrity Data ACA Compliance Solution. Traditionally, Integrity Data will have a release in the December time-frame to update the system for changes required to create and distribute forms to employees.

Note: Form 1095-C is typically due to employees by January 31st.

A subsequent release is to include the necessary changes for electronic filing. These changes are released as soon as possible, but usually no later than 30-60 days prior to the electronic filing deadline.

Note: The typical filing deadline for form 1094-C & 1095-C in printed form is February 28th, while electronic filers have until March 31st. It’s important to remember that all employers with at least 250 forms must file electronically.

Integrity Data uses several mediums for communicating system changes to support new filing years, including customer newsletters, our ACA User Group website and in-application messaging.

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