What is an Applicable Large Employer (ALE)?
An applicable large employer (ALE) is a formal definition established by the Internal Revenue Service (IRS). While the 'rule of thumb' for an ALE is 50+ full-time equivalents, if you're not sure if you met the formal ALE definition for the calendar year, we recommend consulting with a tax advisor or visiting this IRS website.
If your company is an ALE, you are subject to the employer shared responsibility provisions of the Affordable Care Act - also known as the "employer mandate" to offer health insurance coverage or make payments to the federal government. The reporting forms outlined below are used by the IRS to reconcile this responsibility. Note that as of 2023, there are no W-2 reporting requirements for an ICHRA.
What forms do I need to report if I offered an ICHRA last year?
As an applicable large employer (ALE), current regulations require that you:
File a Form 1094-C and accompanying Forms 1095-C with the IRS, and
Provide a Form 1095-C to any employee who is full-time for at least one month during the calendar year.
Employers must report information for all twelve months for each employee on these Forms. Important reminder: the offer of coverage through ICHRA is not taxable, but it may impact an employee’s eligibility for tax credits (if any) from the Marketplace.
What will Take Command Health provide for me to complete my tax forms?
If you had an active ICHRA with us in a given calendar year, we will provide you with a spreadsheet that summarizes some (not all) of the information required to be reported on the Form 1094-C and accompanying Forms 1095-C. We'll make this report available in the documents section of your admin portal and send you an e-mail when it's ready.* Please expect the report in January. Forms and data for the 2025 plan year will become available in early January 2026. Specifically, the summary spreadsheet for the 2025 1094-B/1095-B data will be accessible by the end of the week of January 10, 2026. To locate the 1095 data report and related tax documents:
To facilitate easier access to your ICHRA tax data, follow these steps within the admin portal:
Log in to the Take Command Admin Portal: Sign in to your account using your credentials.
Navigate to the Reports Section: Once logged in, go to the "Reports" or "Reimbursements" section.
Use the Plan Year Filter: Select the relevant plan year for reporting (e.g., 2025).
Download Data Files: Retrieve reimbursement statements, employee-level ICHRA data, or .csv files which contain the necessary information for completing Forms 1094/1095.
Log in to your Take Command admin portal.
Navigate to the Reports or Reimbursements section from the main menu.
Use the "Plan Year" filter to select the relevant year (e.g., 2025).
Download the 1094/1095 tax reports, which are labeled appropriately for easy identification.
On the spreadsheet, we list your eligible employees and some of the required information that should be reported on the Forms 1095-C, according to our records. It’s up to the ICHRA plan administrator (that’s you!) to review the data to make sure that the eligible employee list and required information are complete and accurate. (Hint: if not, it means our records don't match yours, but that's ok! Let us know and we can help get it up to date!)
Troubleshooting Common Data Issues
Administrators might encounter some common issues when working with ICHRA data:
Missing Employees in 1095 Reports: If an employee is absent from the report, ensure their coverage details have been properly uploaded to the admin portal. Once updated, rerun the report to include missing employees.
Insufficient Data Errors: Missing details like employee ZIP codes often cause these errors. Update the incomplete fields in the system and regenerate the report for an accurate version.
This spreadsheet also includes employee-level coverage data, which can assist in the accurate completion of IRS Forms 1094/1095 as required.
To ensure data accuracy prior to filing, employers must:
Review employee details, coverage periods, and other required fields in the downloaded spreadsheet or .csv file.
Verify completeness, paying special attention to employee ZIP codes and other mandatory details. Missing or incorrect data can lead to reporting errors.
The uploaded tax documents reflect the data recorded within the Take Command system as of the reporting date. If discrepancies are noticed, administrators have the flexibility to adjust these forms before submission.
*Note that if you are no longer a Take Command Health client, you can still access this report in your member portal, even though the HRA is no longer active.
When & how do I file these forms?
For the 2025 reporting period, you will need to file your 2025 Form 1094-C and accompanying Forms 1095-C by:
March 2, 2026 if filing on paper (not recommended), or
March 31, 2026 if filing electronically.
You'll also need to furnish the Forms 1095-C to your employees no later than March 2, 2026. You can find specific filing instructions and additional requirements in the Instructions for Forms 1094-C and 1095-C.
Please note: If you are required to file 10 or more information returns during the year, you must file the forms electronically. The 10-or-more requirements apply in the aggregate to certain information returns. Accordingly, a filer may be required to file fewer than 10 Forms 1094-C and 1095-C but still have an electronic filing obligation based on other kinds of information returns filed. The electronic filing requirement does not apply if you request and receive a hardship waiver. The IRS encourages you to file electronically even though you are filing fewer than 10 returns.
Will Take Command complete and file these forms for me?
No. Take Command is not licensed to help our clients with completing, filing or distributing the 1094 / 1095 forms. We recommend working with your payroll provider or tax advisors if assistance is needed.
While Take Command cannot help with completing and filing forms, we recommend ETC. Here's a link to their website.
Employers are encouraged to use the HRA reports and employee-level data from Take Command in collaboration with payroll providers or CPAs for final IRS filings.
Steps After Receiving the Data
After downloading the ICHRA tax data from Take Command:
Review the Provided Data for Accuracy: Check for completeness, such as ensuring the eligible employee list is correct and aligns with company records.
File the IRS Forms: Use the spreadsheet to complete IRS Forms 1094-B and 1095-B for small employers, or 1094-C and 1095-C for ALEs.
Distribute Employee Forms: Ensure appropriate forms (1095-B for small employers and 1095-C for ALEs) are distributed to employees by the IRS-mandated deadlines.
What if I do not have 50+ employees?
Not an ALE? Please see our help article for employers with less than 50 employees offering an ICHRA for more information on the tax reporting you are required to file.
Looking for more info on the codes?