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ACA FAQ - Forms

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What forms are used in the ACA process?




An IRS reporting form titled "Transmittal of Health Coverage Information Returns," the 1094-B summary form that accompanies the more detailed 1095-B which provides coverage plan information about employees to the IRS.

Filers will send form 1094-B (transmittal) with form 1095-B (returns) to the IRS.


The 1095-A form is provided by insurance companies to anyone who receives coverage from a health care exchange.


The 1095-B form is provided by employers with less than 50 FTEs who offer self-funded health coverage.

An IRS reporting form titled "Health Coverage," form 1095-B is used to report certain information to the IRS and to taxpayers about individuals who are covered by minimum essential coverage and therefore aren't liable for the individual shared responsibility payment.

Minimum essential coverage includes government-sponsored programs, eligible employer-sponsored plans, individual market plans, and other coverage the Department of Health and Human Services designates as minimum essential coverage. Minimum essential coverage is described in more detail under Who Must File, later.

Additional information about minimum essential coverage and the individual shared responsibility provision is at


An IRS reporting form titled "Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns," the 1094-C is the employer's filing cover sheet sent to the IRS to summarize the 1095-C. Form 1094-C must be filed when an employer files one or more Forms 1095-C. The 1094-C summarizes and accompanies the 1095-C.

Employers with 50 or more full-time employees (including full-time equivalent employees) in the previous year use Forms 1094-C and 1095-C to report the information required under sections 6055 and 6056 about offers of health coverage and enrollment in health coverage for their employees. 


An IRS reporting form titled "Employer-Provided Health Insurance Offer and Coverage," the 1095-C form is provided by employers with 50 or more FTEs. The 1095-C provides information about health insurance and is sent from a company to both employees and the IRS to show proof of insurance. Much like the Form W-2 is used to determine whether or not you owe taxes, the IRS will use the information reported from your Form 1095-C to determine whether you (or your employer) may have to pay a fine for failing to comply with the Affordable Care Act. Applicable Large Employers (ALEs), or employers with 50 or more full-time equivalent employees, are required to send Form 1095-Cs to all full-time employees (those who work an average of 30 or more hours per week) as well as any employee who was enrolled in their health insurance plan.

Applicable Large Employer Members (ALE - employers with 50 or more FT employees in the previous year are required to file Form 1095-C. Every employee of an ALE who is eligible for insurance coverage should receive a 1095-C.

Employers with 50 or more full-time employees (including full-time equivalent employees) in the previous year use Forms 1094-C and 1095-C to report the information required under sections 6055 and 6056 about offers of health coverage and enrollment in health coverage for their employees.

For each full-time employee of an employer, there must be only one Form 1095-C filed for employment with that employer. For example, if an employer separately reports for each of its two divisions, the employer must combine the offer and coverage information for any employee who worked at both divisions during the calendar year so that a single Form 1095-C is filed for the calendar year for that employee which reports information for all twelve months of the calendar year from that employer.


The Affordable Care Act, or Obamacare, includes both the individual mandate and the employer mandate.


  • The individual mandate requires that most Americans have qualifying healthcare coverage or potentially face a fine.
  • The employer mandate requires employers with 50 or more full-time equivalent employees to offer healthcare coverage to their full-time employees or potentially face a fine. 


The Form 1095-C contains important information about the healthcare coverage offered or provided to you by your employer. Information from the form may be referenced when filing your tax return and/or to help determine your eligibility for a premium tax credit. Think of the form as your “proof of insurance” for the IRS. You do not need to send a copy of your 1095-C to the IRS when filing you tax return, however, you should keep the form with your tax records.



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How many pages will print for our 1095s in 2016/2017?

We have updated this so that now it will print on only 2 pages unless there is an overflow due to dependents listed.



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Can we print our 1095s double-sided?




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When and how do we deliver our 1095s to the IRS?

Electronic filing is due at the end of March 2017. We have a partnership with Greenshades. As far as Greenshades packages, we have a basic package based on number of states annual filings, 1094, 1095 W2, 940, state unemployment and 941. When filing electronically, you do not have a separate 1094. Avionte offers two packages:

  • Quarterly - we help you file. We send you a tax summary report, we have you approve it. We do the filing as if you were doing it yourself.
  • Weekly pkg - we come in after payroll and run the taxes summary report and pay the taxes due that current week for your company. Many states are due the 15th of the month so you'll need to note when the due dates are for your specific states and agencies. With a 941, they want the payment before the due date. The tax summary report is very valuable to you for this type of info.

If you are filing in a new state, please let us know. Greenshades also must be told about any new states that need to be added.



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We offer a MEC plan to all employees, FT & PT at time of hire.  If an employee is placed on assignment starting 11/15/16 would we report the offer of coverage on the 1095-C in the month following their assignment start date, which would be Dec. 2016?

Some plans may have a wait period, etc so we don't know when the coverage would begin. However, the 1095 will only show full months of coverage. So in this case December would be the first full month of coverage if an offer is in place.



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In the ACA Companion application, what does Certification of Eligibility refer to in the ACA Employer setup?

That refers to line 22 of the 1094-C. Visit the IRS ACA instructions at



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Regarding 1095-C generation, we do not track full-time vs part-time employees. Our company simply offers coverage to all new starts and they are eligible to begin coverage once they have been employed with us for 60 consecutive days. We had a custom AQ created to generate a list of these employees. I would like to know what kind of workaround you'd generate for the ACA package. Thanks!

ACA tracking should still work for you. We neeed to know who the 1095 should be produced for. How are we determining who is full time? We recommend that within Avionté's tracking, create a lookback period. You can do this manually by setting everyone to "Yes" (indicating a Full Time status) or setting a 3 - 12 month lookback period. We recommend a 12 month lookback.



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Can companies mail W2s and 1095-Cs together?
Yes, they can be mailed together. If you are outsourcing, check with your vendor as most require separate mailings because they are pressure sealed.



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What is the difference between form 1095-C and 1094-C?
The main difference between these forms is that the 1095-C provides information about health insurance and is sent to both employees and the IRS, while the 1094-C acts as a cover sheet about the 1095-C and is sent only to the IRS.



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How are 1094s and 1095s printed in Avionté?

Visit the ACA - Print 1094-C and 1095-C article for printing details. 



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Who should receive a 1095-C form in January 2016?

There are two requirements to receive a 1095C:

  1. Any employee who was enrolled in a self-insured plan regardless of PT or FT status should receive a 1095C.

  2. Any employee who was full time or set to "Yes" for ACA eligibility for at least one month within the calendar year even if they underwent a qualifying break in service later on in the year should receive a 1095C. 

If coverage was accepted, a contribution/deduction is entered. If coverage was declined, a $0 contribution is entered (including the start and end date that coverage was available had they accepted the offer).



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Do part time employees also receive a 1095-C?
It depends on the type of plan the company is offering.

The company will complete parts I, II, and III for full time employees and those enrolled in coverage (whether full time or not).

Fully Insured:
You will complete parts I and II only (not part III) to full time employees.
More information can be found on the IRS website for 1095C instructions:



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Is there a report that can be run to find out who will be receiving a 1095-C at the end of the year?
The 1095C AQ is available through the Avionté Reports option in the Main Menu. However, for the most up-to-date ACA tracking logic and functionality, you must be using version 14.2.6 or newer. You can use the ACA Census AQ and filter on "Yes" for eligibility. A 1095-C will generate for all employees with the ACA eligible value marked as "Yes."



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Will the 1095-C form be available to employees through the Avionté employee portal like the W2s are?
The 1095-C form will not be available through the Employee Portal for 2015 filing. This may be an option in 2016. At this time, 1095-C filing needs to be completed outside of the context of Avionté.

Note: Per IRS regulations, if you are filing for more than 250 employees, you must file electronically and when filing electronically a separate consent must be obtained. Electronic filing may be outsourced with Greenshades, IBF, Nelco or a similar provider. Our product specialists will be happy to explain the ACA packages offered by Avionté.



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What forms are available through the Greenshades integration? 

The 1095-C and 1094-C forms are available in Greenshades. The 1095-B should come from the insurance provider or certain self-insured employers. A summary and status of the filings is available when logging into or with your login credentials. 



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If there are errors on 1095-Cs can they be corrected per individual 1095-C and reprinted per single corrected form?
Yes, the 1095-C can be regenerated then reprinted.



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Are 1094-C & 1095-C stored anywhere or do we need to keep a hard copy for our records?
The data is stored in Avionté and pulled each time a report is generated. You can save the report as a PDF for your own records or share it with a 3rd party.



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Can you explain how to process 1095-Cs if we are NOT utilizing Greenshades?
Avionté recommends using the Greenshades solution, however an XML feed can be generated and submitted to a 3rd party vendor such as Avionté partners Nelco and IBF. The GenerateSeparateGSXMLFile property should be set to "True" to generate the XML feed. Avionté clients also have the option to print 1095-Cs from a report, similar to W2s, in which case, a 3rd party vendor is not needed. Please contact an Avionté Product Specialist for details on available package options.



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What if our payroll is outsourced and that vendor is unable to produce our 1095-Cs. What do I need to do to utilize Avionté? Can Avionté accept an import or do I have to manually enter their information? If it is manually, how is this completed?
Yes, Avionté can create an import however, it would be billable time. Please create a ticket in the Avionté Support Center and our Tech Services team can assist with this.



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We are an ALE (Applicable large Employer) but only a small percentage of employees enrolled in our MVP/MEC plans. The rest declined it. Do we have to send a 1095-C to just those enrolled or all employees who were offered coverage?
If you are self-insured, then you will complete parts I, II, and III for full-time employees and those enrolled in coverage (whether full time or not).

If you are fully insured, then you will complete parts I and II only (not part III) to full-time employees.

More information can be found on the IRS website for 1095C instructions:

All of those set to "ACA eligible Yes" in Avionté will get the 1095-C. If the employee declined coverage, you will still need to report that the offer was made by entering a $0 Contribution.

Note: A lack of response can be considered a declination as long as it is set as a $0 contribution and noted as a declination under the employee record.



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If the ACA determination wasn't set until late in the year, will the 1095-C reporting still function properly?
1095-C reporting will function accurately for those employees who started their assignment AFTER the ACA-related Admin Tool properties tracking the employee’s eligibility status were configured. If these tracked employees became eligible at any time during the year, the period that they were covered under a qualifying plan will be captured.

However, those employees on assignment prior to ACA tracking, or set up incorrectly for tracking, will not be accurately reported. In addition, changing their status manually will not calculate retroactively. Contact Avionté to schedule an ACA recalculation.




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We offered the MEC plan to all employees. No part-time employees enrolled and only a portion of our full time employees respond. Who needs a 1095-C?
All full time and ACA eligible employees require the 1095-C. Whether they enrolled in the plan or not, they were still ACA eligible.

Only those part-time employees that have actually enrolled in the offered plan require a 1095-C.



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We offered all of our temps a self-insured plan. We do not want to measure whether they are FTE. Would this require us to file the 1094C and 1095C and can we send a 1094-C/1095-C to everyone?
Yes, assuming you are an ALE, you will be required to file both forms. The 1094-C is the employer’s filing to the IRS. The 1095-C is given to the employee. You should provide a 1095-C for any employee that enrolls in coverage (whether full time or not) and to all full time employees. More information can be found on the IRS website for 1095C instructions:



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We are qualifying for ACA January 1st 2016. Do we still have to send 1095-C reporting to our employees and pertaining to the 1094-C reports, does our carrier generate them?
An ALE with 50 or more full time employees (including full time equivalent employees) must produce a 1095-C for 2015. Whether you are fully insured or self-insured will determine who produces the form.



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Which reports are required by the IRS for a company not offering Health Insurance to employees (no play) due to low numbers of full-time employees in 2015?
This depends on if you are an ALE or not. If you are not an ALE (have less than 50 full-time employees) and offered no coverage than no reporting is needed. If you are an ALE (have 50 or more full time employees), you are still required to report the 1095-C and 1094-C.



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What is used to calculate column B of the 1094-C part III (full-time employee count for ALE Members). Is there a report I can run to verify the monthly number?
To get an accurate count of full time employees, run the 1095C AQ and filter on the properties per month.



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We are a PEO employer of record for W2 purposes but clients have their own insurance plan. Do we have to provide a 1095-C for them or will their insurance carrier do that?
As the employer on file (the employer producing the paycheck), you will need to produce the 1095-C.



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Will we have the ability to manually adjust any 1095-Cs like we do with the W2?
Yes, you can make necessary edits in the Employee Extra fields. If you are using Greenshades or another vendor, you must regenerate the XML to include any updates before sending it to the vendor.



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Do we need to include a cover letter or the instruction sheet with the 1095-C to explain what it is, and why our employees are receiving it?
It is advised to include the instruction sheet for the 1095-C or a specialized cover letter since it is the first year that the form is in use. Avionté does not currently provide any resources for creating such a cover letter.



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Is date of birth important for 1094-C & 1095-C forms?
It depends. If you are self-insured then you will need the SSN or DOB (Avionté recommends collecting the DOB) for dependents that are covered under your plan. These will be reported in Part III of the 1095-C. If you are not self-insured you will not need DOB for reporting purposes.



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I am an ALE but not offering Health Insurance at all. Who will we send 1095-Cs to? And how will we fill out our 1094?
You will need to send a 1095-C to each employee who was ACA eligible at any time in 2015. On your 1094-C you will complete Part I and Part I as normal, and complete Part II to reflect the monthly totals for the B and C column.


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If an employee has several open assignments, does the Total Employee Count regard each assignment as a separate employee?

No, each SSN is only ever counted once for a given FEIN.


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If someone's ACA eligibility is set to "Yes," but they aren't working in a particular month, would they show up in the Full Time Employee Count?

As long as the system considers them as eligible for an offer of coverage for a given month they will be counted. Remember that setting an employee to ACA Eligibility "Yes" just triggers the system to set their Effective Insurance Date which is currently the primary driving factor for the dates in which an employee is considered eligible. Additionally the employee must be outside of their Limited Non-Assessment Period/Measurement Period.


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If an employee became eligible for insurance on March 1st and they were working, would they continue to show up in each subsequent month? 

Yes. It's displaying months an employee is eligible, not just the month an employee became eligible.


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What if a full time employee's hours dropped to part-time?

Once an employee is no longer considered eligible for an offer, they would no longer be counted. The system recognizes an employee to be considered ineligible after a valid break in service, after their termination date, or after their stability period ends following a completed measurement period determines them non-FT.



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If we don’t get a declination, will it default to “not elected” on the 1095-C?

If there is no declination recorded then the 1095-C will reflect that there was no offer of coverage made to the employee.


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When running, and printing the 1094 and 1095 reports, do we need to print on specially ordered papers forms?

A: No, you can use normal 8.5 x 11 sized paper.



Will line 16 reflect correctly when looking at employees that go off and on assignment? Will we need to use the override options in the core app at all?

A: Line 16 will look at assignment dates to determine when the employee worked for you. The overrides are still an option for you if you need to change any of the info on the 1095C for line 14, 15 and 16.

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