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February 14, 2025 By Mark

Understanding IRS Code 1094C-038-03: Inaccurate Offer of Coverage Code

Understanding IRS Code 1094C-038-03 Inaccurate Offer of Coverage CodeIRS Code 1094C-038-03 addresses errors related to the Offer of Coverage Code reported on Form 1094-C. This code plays a crucial role in indicating the type of health insurance coverage offered to employees and is vital for complying with the Affordable Care Act (ACA) mandates.

Significance of the Offer of Coverage Code

The Offer of Coverage Code provides the IRS with details regarding the health coverage offered by an employer. An incorrect code may suggest that an employer did not offer appropriate or sufficient health insurance to their employees, potentially leading to penalties.

How to Address Errors Under Code 1094C-038-03

  • Review the codes entered on your Form 1094-C to ensure they accurately reflect the coverage offered to employees throughout the reporting year.
  • Consult ACA guidelines to verify the correct codes for the type of coverage you provided.
  • Amend your filing with the correct Offer of Coverage Codes and submit the revised Form 1094-C to the IRS.

Tips for Preventing Future Errors

To minimize the risk of similar errors in future filings:

  • Keep detailed records of the health coverage options provided to employees, including plan details and employee coverage selections.
  • Train your HR and payroll staff on ACA reporting requirements and the significance of accurate code entry on IRS forms.
  • Utilize ACA compliance software to streamline the filing process and reduce the likelihood of errors.

Getting Help

For additional support with ACA reporting and understanding the complexities of Offer of Coverage Codes, visit ACA Track’s FAQ page or consult with an ACA compliance expert.


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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