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ACA reporting, explained

ACA software and 1095-C FAQs.

Answers to common questions about ACA requirements, your data, diagnostics and filing.

52 questions across 6 topics

01 / FAQ

ACA basics & company requirements

What is ACA reporting?

ACA reporting documents health coverage offers and, where required, enrollment. Applicable large employers report through Forms 1094-C and 1095-C; other coverage providers may use Forms 1094-B and 1095-B. IRS guidance ↗

What is an applicable large employer (ALE)?

Generally, a company is an ALE when it averaged at least 50 full-time employees, including full-time equivalents, during the preceding calendar year. This determines the following year’s ALE status; a current headcount alone is insufficient. IRS guidance ↗

How do part-time employees affect the ALE calculation?

For each month, add non-full-time employees’ hours, capped at 120 per employee, and divide by 120. Add those equivalents to the full-time count, then average the monthly totals over the year. Equivalents count toward ALE status; they are not individual full-time employees. IRS guidance ↗

Do related companies count together?

Commonly controlled or otherwise related employers may be combined to determine ALE status. Each ALE member generally reports under its own EIN. Review ownership and group relationships before treating a company as below the threshold. IRS guidance ↗

Are new companies and seasonal employers treated differently?

New employers have a special expected-and-actual workforce test. A seasonal-worker exception may apply if the workforce exceeds 50 for no more than 120 days and seasonal workers account for the excess. Seasonal-worker and seasonal-employee rules differ. IRS guidance ↗

Who is a full-time employee for ACA purposes?

Generally, an employee averaging at least 30 hours of service per week or 130 per month is full time. Hours of service can include paid time off, not just hours physically worked. Payroll labels alone do not determine ACA status. IRS guidance ↗

What is the difference between monthly and look-back measurement?

Monthly measurement evaluates hours each month. The look-back method uses a measurement period to determine status for a subsequent stability period, subject to detailed rules. The look-back method does not determine whether a company is an ALE. IRS guidance ↗

What coverage does an ALE need to offer?

Employer shared responsibility rules can impose payments when coverage is not offered to at least 95% of full-time employees and their dependents, or when offered coverage lacks affordability or minimum value, and a full-time employee receives a Marketplace premium tax credit. Meeting the offer threshold alone does not eliminate every potential payment. IRS guidance ↗

What do affordability and minimum value mean?

Affordability evaluates the employee’s required contribution under the applicable rules. Employer safe harbors can use W-2 wages, rate of pay, or the federal poverty line; the percentage changes annually. Minimum value generally requires at least 60% actuarial coverage and substantial inpatient hospital and physician services. Confirm your plan’s status and the year’s rules. IRS guidance ↗

Does a company below 50 employees have no reporting duties?

Not necessarily. A non-ALE sponsoring self-insured coverage may still have coverage reporting obligations, generally using the B-series forms. State obligations may also apply. Confirm the correct form series and supported workflow with our team before starting. IRS guidance ↗

02 / FAQ

Forms, monthly codes & complex coverage

What is the difference between Form 1094-C and Form 1095-C?

Form 1094-C summarizes the employer’s reporting and transmits employee returns. Form 1095-C reports employee-level offers of coverage and related information. An authoritative 1094-C includes employer-wide information. IRS guidance ↗

What do the 1095-C codes on Lines 14, 15 and 16 mean?

Line 14 identifies the coverage offer. Line 15 reports the required employee contribution when applicable. Line 16 explains enrollment, employment status, safe harbors, or other applicable relief. These are monthly determinations. IRS guidance ↗

Does ThousandSquared assign the 1095-C codes automatically?

Yes. The software uses your company questionnaire, employee records, payroll hours, and insurance census to automatically apply monthly 1095-C codes and applicable Line 15 amounts. Your team reviews the results and resolves exceptions rather than manually coding every employee month.

Why might codes change from month to month?

Hires, terminations, changes in full-time status, coverage offers, enrollment, and plan arrangements can change an employee’s monthly circumstances. Accurate effective dates and company settings help the software distinguish those months.

How is self-insured coverage handled?

Self-insured ALE reporting includes covered individuals in Part III, including applicable enrolled employees and dependents. Fully insured employers generally leave Part III to the insurer’s coverage reporting. Self-insured non-full-time enrollment can also require reporting. IRS guidance ↗

Can the software handle ICHRA arrangements?

The platform supports ICHRA-related reporting. Configure the arrangement and supply the relevant employee and coverage information before reviewing the resulting codes and amounts. Missing ICHRA configuration can produce a diagnostic exception. Contact our team when your arrangement requires additional review.

What about COBRA, union plans, and unusual employee situations?

The workflow includes checks for COBRA, union, coverage, and employment-date inconsistencies. These situations require accurate source information and appropriate company settings. Have the team review unusual arrangements instead of assuming one code applies to every situation.

Can I review or override the automatic results?

Yes. The 1095-C Review screen provides monthly results and identifies system-generated and user-modified information. Review the underlying facts before applying an override, record the reason, and recheck the forms after changing source data or settings.

03 / FAQ

Getting started & preparing your data

What information should I have ready?

Company setup: legal name, EIN, address, reporting year, plan details, waiting period and employee contribution amounts.

Employee records: names, full SSNs, mailing addresses and hire dates. Include termination dates when applicable.

Hours or status: monthly hours, annual hours, or an employer-provided full-time (FT) / part-time (PT) classification. Also provide actual insurance coverage dates or monthly enrollment records, plus employee classes and special situations where applicable.

What does the company questionnaire cover?

The brief questionnaire establishes company and coverage settings, including employee classifications, eligibility and measurement practices, plan arrangements, and applicable special programs. Answer it using your actual policies; these choices influence the automated reporting results.

Can ACA software import my payroll and insurance Excel reports?

Yes. Use existing payroll and insurance reports or our optional templates, then review the detected columns before confirming an import.

Download the employee and hours Excel template — includes Jan–Dec monthly hours, annual hours, FT/PT classification, insurance census and covered-family tabs.

Download the insurance census Excel template — includes employee coverage dates and covered-family records. Delete the fictional sample rows and skip the Guide tab when importing.

Do I need the entire year’s information?

Provide information for the reporting year and any earlier periods needed to establish eligibility or measurement status. Include hires, terminations, coverage changes, and relevant prior-year history. A year-end snapshot may miss important monthly differences.

What employee demographic details matter?

Use complete names, full SSNs, mailing addresses and hire dates. Keep the same employee identifier across files. An import may accept a missing field that must be corrected before automatic generation. Employee DOB is needed for ICHRA pricing and where covered-person identification requires it; include it when applicable.

What if payroll and insurance reports disagree?

Reconcile employee identifiers, employment dates, coverage dates, and classifications against the original records. Diagnostics can help identify discrepancies, but the company must confirm the correct facts. Regenerate and review the affected results after resolving them.

Can I manage more than one company?

The application organizes reporting by company. Keep EINs, reporting years, source records, and company settings separate, and confirm related-company relationships where relevant. Contact our team about your multi-company workflow.

Do I need monthly hours and exact coverage dates?

Provide monthly hours, annual hours, or an employer-provided FT/PT classification; you do not need all three. Monthly hours are preferred when status changes during the year. The template has a separate Hours Jan through Hours Dec column, an annual Hours Total column, and FT PT Status on the Employees tab.

For insurance, provide actual coverage start and end dates or monthly enrollment records. Leave the end date blank for ongoing coverage and use separate rows for separate coverage periods.

What extra information do self-insured and ICHRA plans need?

For applicable covered-person reporting, provide each enrolled family member’s name, SSN or DOB when SSN is unavailable, and coverage periods. ICHRA also needs employee DOB, allowance details and the applicable residence or work location, with county confirmation where needed. Configure the plan and eligibility rules in the questionnaire.

04 / FAQ

Diagnostics & reviewing your results

What does the Diagnostics screen do?

Diagnostics highlights missing information and inconsistencies that can affect coding or filing. It helps your team focus its review on exceptions rather than inspecting every source record manually. Review the category, severity, and status of each item.

What kinds of problems can diagnostics identify?

Examples include missing or invalid SSNs, incomplete names or addresses, duplicate records, missing hire dates, invalid coverage ranges, hours or coverage before hire, coverage after termination, missing employee classifications, and incomplete covered-individual information.

Does it check coverage and special arrangements too?

Checks also address missing hours, inconsistent monthly full-time information, coverage gaps, COBRA inconsistencies, unrecognized special-program information, and ICHRA arrangements without configuration. A flag identifies something to investigate; it does not by itself establish the final tax treatment.

How should I resolve a diagnostic item?

Open the affected employee or source information, investigate the original records, correct the underlying data or company setting, and update diagnostics. Then review the affected 1095-C months and employer totals again. Avoid changing a code merely to clear a warning.

What is the difference between a warning and a filing blocker?

Severity helps prioritize review. Some items require attention but may not stop every workflow; missing required filer information or failed filing validation can block the filing step. Follow the specific message and resolve required items before submission.

Does a clean Diagnostics screen guarantee compliance?

No. Diagnostics evaluates available data and configured rules. It cannot establish facts absent from your records or guarantee IRS acceptance, correct plan administration, or exemption from penalties. Review company settings, forms, and filing acknowledgements as separate steps.

What should I review on the 1095-C and 1094-C screens?

On 1095-C, review employee identity, monthly codes and contributions, overrides, and covered individuals where applicable. On 1094-C, review employer identity, form counts, monthly workforce and coverage totals, and authoritative or aggregated-group selections. Compare the results with your company records.

05 / FAQ

Filing, deadlines & employee access

What are the main steps to complete a filing?

Complete company setup, import and reconcile data, resolve diagnostics, review Forms 1095-C and 1094-C, confirm filer information, and review the price before authorizing filing. After submission, track acknowledgements, resolve errors, and arrange employee statements and applicable state filings.

Does generating a PDF or XML file mean the return is filed?

No. Generation, submission, and acceptance are separate stages. A downloaded PDF or XML file alone does not prove delivery to the IRS. Confirm a production submission and its acknowledgement; test transmissions do not satisfy a live filing obligation. IRS guidance ↗

When are federal ACA returns due?

Generally, electronic filing is due March 31 after the reporting year; paper filing, when permitted, is due February 28. Weekend and holiday adjustments apply. Employee-statement deadlines differ. Check the instructions for the specific year before planning your filing. IRS guidance ↗

When is electronic filing required?

Generally, the threshold is 10 information returns, aggregated across covered return types—not just Forms 1095-C. Review the applicable rules and any authorized waiver before choosing paper filing. IRS guidance ↗

Do I need my own IRS transmitter control code (TCC)?

IRS AIR transmission requires an authorized transmitter setup. Whether your company needs its own TCC depends on who transmits your returns. Confirm the DIY or managed arrangement with our team; do not assume every customer must obtain a separate TCC. IRS guidance ↗

What do IRS acknowledgement statuses mean?

Processing means the IRS has not finished. Accepted means the transmission was processed without an error file. Accepted with Errors requires review of reported issues; Partially Accepted can include rejected submissions. Rejected means processing failed. Keep the acknowledgement and resolve the specific issues. IRS Publication 5165 ↗

How are rejected returns and corrections handled?

A rejected submission and a correction to an accepted return require different workflows. Review the acknowledgement first. ThousandSquared’s filing options include rejection review or resubmission support; contact the team to confirm the correct action and any correction-service scope. IRS Publication 5165 ↗

Is state filing the same as federal filing?

No. State reporting can involve separate formats, registrations, authorizations, deadlines, and acknowledgements. ThousandSquared offers applicable CA, NJ, DC, and RI filing and Massachusetts 1099-HC services. Confirm your company’s requirement and the submission route; generating a state file is not proof of state acceptance.

Can employees retrieve their 1095-C online?

Yes. Available 1095-C PDFs can be accessed through the dedicated employee retrieval portal. Confirm that the forms are available and that employees have the appropriate instructions. The portal link appears in the footer of this website.

Does the portal replace employee-statement requirements?

Portal availability alone is insufficient. An alternative furnishing method requires a clear website notice, timely delivery upon request, and compliance with the applicable notice and response rules. Other electronic delivery may require consent. Confirm federal and state requirements for the reporting year. IRS Notice 2025-15 ↗

What if I missed a deadline or received an IRS notice?

Contact our team promptly to discuss prior-year reporting, corrections, or notice-response assistance. Preserve the notice and filing records and identify its response deadline. Do not assume a later filing automatically resolves a proposed assessment. IRS guidance ↗

06 / FAQ

Service options, pricing & data protection

Can I use the software myself or have your team handle it?

Both options are available. DIY Automated Filing lets your team manage setup, imports, review, and filing. Managed Filing adds human pre-filing review, filing administration, acknowledgement monitoring, rejection assistance, and priority support.

How much does 1095-C ACA filing software cost?

Federal pricing uses the total number of Forms 1095-C for one employer and tax year. The applicable volume rate applies to all those forms, subject to that tier’s minimum charge. DIY starts at $249; Managed Filing starts at $495. Compare federal and state filing costs.

Is state e-filing included with the ACA software?

State filing is an add-on for DIY customers. Managed Filing includes one applicable state filing; additional states have separate charges. State minimum charges apply. See state filing prices.

Who is responsible for the source information?

Your company remains responsible for the accuracy and completeness of the employee, payroll, benefits, and company information supplied. Automation and managed review help with preparation; they do not replace accurate company records.

How should I provide sensitive employee information?

Use the secure application and approved data-transfer workflow. Keep SSNs, payroll information, and health or coverage records out of public website forms and ordinary inquiry emails. Contact the team for the appropriate transfer instructions before sending sensitive files.

What about HIPAA and security requirements?

ACA data can include PII and, depending on the arrangement, protected health information. Discuss your company’s privacy requirements, security documentation, and any applicable business associate agreement with our team before uploading sensitive records. Confirm the safeguards and contractual requirements relevant to your situation.

How can I get help with a complex question?

Contact our team with a general description of your question, company size, and reporting year. We can discuss the software, managed filing, and ACA consulting. Share sensitive employee details only through the approved secure workflow.

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