If you are an Applicable Large Employer (ALE) offering an ICHRA, you must file IRS Forms 1094-C and 1095-C to report your health coverage offers and employee eligibility, and provide Form 1095-C to all full-time employees, even if they are enrolled in or waive the ICHRA.
What is an Applicable Large Employer (ALE)?
An Applicable Large Employer (ALE) is generally an employer that had an average of 50 or more full-time employees (including full-time equivalents) in the previous calendar year.
If you are an ALE:
You are subject to the ACA Employer Shared Responsibility provisions
You must offer affordable, minimum value coverage or potentially owe penalties
You must file annual information returns with the IRS
What forms must an ALE file when offering an ICHRA?
If you are an ALE offering an ICHRA, you must file:
Form 1094-C (transmittal form submitted to the IRS)
Form 1095-C (individual form for each full-time employee)
You must:
File Forms 1094-C and 1095-C with the IRS
Provide Form 1095-C to each full-time employee for at least one month during the calendar year
Report coverage offer information for all 12 months of the year for each employee
Do I need to file 1095-C forms for employees who do not enroll in the ICHRA?
Yes. You must file Form 1095-C for each full-time employee, regardless of whether they:
Enroll in the ICHRA
Waive coverage
Enroll in a spouse’s or other employer plan
Decline coverage entirely
The 1095-C reports the offer of coverage, not just enrollment.
What does Form 1095-C report for an ICHRA?
Form 1095-C is used to report:
Whether you offered ICHRA coverage to the employee
Whether the offer was affordable under IRS rules
Whether the employee enrolled in coverage
Coverage information for self-insured arrangements (if applicable)
This data is also used by the IRS to determine:
Employer Shared Responsibility penalties (if applicable)
Employee eligibility for Premium Tax Credits
What is Form 1094-C used for?
Form 1094-C is the transmittal form that:
Summarizes all Forms 1095-C filed by the employer
Reports aggregate employer-level information
Identifies the employer as an ALE
Is submitted to the IRS along with 1095-C forms
Only one 1094-C is designated as the “authoritative transmittal.”
What are the filing deadlines for ALE reporting?
For ALEs, typical deadlines are:
March 2 (paper filing, including employee distribution of 1095-C)
March 31 (electronic filing with the IRS)
Most ALEs are required to file electronically if submitting 10 or more information returns.
Does Take Command file or submit these forms for me?
No. Take Command does not:
Complete IRS Forms 1094-C or 1095-C
File forms with the IRS
Distribute employee tax forms
We provide:
Reporting summaries
Employee-level ICHRA data
Exportable files to support your CPA, payroll provider, or filing service
What data does Take Command provide for ALE reporting?
If you had an active ICHRA, Take Command provides:
Employee eligibility and participation data
Coverage offer information by month
Allowance and reimbursement history
Exportable spreadsheets and CSV files for IRS reporting
These reports support completion of Forms 1094-C and 1095-C.
What happens if my ALE data is incorrect?
You are responsible for reviewing and validating:
Employee lists
Coverage offer information
Monthly eligibility data
Employer classification and EIN accuracy
Errors in reporting can lead to:
Incorrect IRS filings
Potential penalties under ACA employer mandate rules
Employee tax credit miscalculations
You should reconcile Take Command data with internal payroll and HR records before filing.