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February 14, 2025 By Mark

Resolving IRS Code 1094C-023: Discrepancies in Employee Count on Form 1094-C

Resolving IRS Code 1094C-023 Discrepancies in Employee Count on Form 1094-CIRS Code 1094C-023 is triggered when there are discrepancies in the employee count reported on Form 1094-C. Accurate employee count is crucial for determining an employer’s obligations under the Affordable Care Act (ACA).

Importance of Accurate Employee Count Reporting

An accurate count of full-time employees and full-time equivalent employees is essential for:

  • Determining whether an employer is subject to the employer mandate.
  • Calculating potential penalties for non-compliance with coverage requirements.
  • Ensuring correct data submission to the IRS for compliance purposes.

Common Causes of Employee Count Discrepancies

Discrepancies in employee counts can arise from:

  • Errors in data aggregation from multiple sources or payroll systems.
  • Misclassification of employees between full-time and part-time statuses.
  • Lack of updating employee status changes in reporting systems.

Steps to Correct Employee Count Discrepancies

To address and correct issues flagged by Code 1094C-023, employers should:

  • Conduct a thorough review of all employee records to verify the accuracy of the count.
  • Update any incorrect information in the ACA reporting tools and systems.
  • Amend the Form 1094-C with the corrected employee count and resubmit to the IRS.

Tools and Resources for Accuracy

Employers can enhance their compliance efforts using tools like ACA-Track, which helps manage employee data accurately. For additional assistance:

  • The Official IRS website offers comprehensive guidelines on reporting requirements and how to correct discrepancies.
  • The Common 1094-C error codes page provides further insights into common issues and corrective actions.


Filed Under: ACA Compliance

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Information provided by PSST, LLC concerning the Affordable Care Act is not legal advice and should not be treated as such. If you have questions about how the Affordable Care Act will affect you as an employer, please consult legal counsel.

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