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Need to Correct an IRS 1094-C or 1095-C Form?

Points North • May 14, 2019
You’ve completed your reporting obligation for the Affordable Care Act. How do you know if you need to file a correction?

That depends on the error. There are errors that need to be submitted as corrections and others that do not require filing a correction. For this discussion, let’s assume there are errors that require corrections.

1094-C Corrections
The first thing to note is that a 1094-C is only marked as “Corrected” if there is an error on the 1094-C form itself. That means that a data element on the 1094-C was incorrect, such as the legal company name, not information on one of the accompanying 1095-C forms.

The 1094-C form is not considered a correction by the IRS if it is being submitted as the cover page for one or more corrected 1095-C forms. The accompanying 1094-C form is simply a new form and the data on it should reflect what is being submitted with it (e.g., if 1 form needs correcting, Line 18 on the 1094 form will state “1” even though hundreds of forms were submitted originally).

It’s important to note that if a submission was “Rejected” by the IRS, employers should NOT mark the original submissions as corrected when resubmitting. Corrections only take place when you are changing data elements on a form.

The table below describes the errors that must be corrected:
1095-C Corrections
Only 1095-C forms that have been filed with the IRS are considered “Corrected.” If you have furnished the 1095-C form to the recipient but have not filed the form with the IRS, the “Corrected” box should not be checked. Instead, simply write, type, or print “CORRECTED” on the new Form 1095-C and furnish it to the recipient. The form will be considered an original version when it is submitted to the IRS.

IMPORTANT: Enter an “X” in the “CORRECTED” checkbox only when correcting a Form 1095-C previously filed with the IRS.

If the 1095-C has been submitted to the IRS and an error is noted, the “Corrected” box at the top right must be checked in order to notify the IRS that the form has been updated and is being resubmitted as a correction.

The table below shows the types of corrections that must be submitted to the IRS:
When to Make Corrections
Quite simply, a corrected return should be filed as soon as possible after an error is discovered.

For additional information on filing corrections, visit the IRS site (irs.gov) or refer to the instructions at https://www.irs.gov/pub/irs-pdf/i109495c.pdf.
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