1094-C Part II Review Checklist

Read the line 19 designation and the employer's filing map before reviewing Part II. The 2025 instructions limit lines 20 through 22 to the authoritative transmittal. A form carrying only a nonauthoritative batch should not acquire employer-summary entries through a copied template.

Confirm the employer's legal name, EIN reference, reporting year, and approved designation. If more than one provider prepares forms for the employer, obtain the shared mapping that identifies which transmittal carries its aggregate information.

Pause a field-level approval when the authoritative designation is unresolved. A correct number placed on the wrong transmittal is still a structural problem. Use the authoritative-transmittal map to resolve the scope first.

Line 20 concerns the total Forms 1095-C filed by or on behalf of the ALE member. It can include forms transmitted with other batches. The line 20 instructions explain the employer-wide scope.

Obtain the reviewed batch register and reconcile its complete annual records. Keep the line 18 count for this transmittal separate. Investigate records appearing in two provider files and records not assigned to any batch before using the total.

Record whether a later update changes the employer population or merely reallocates records between batches. Moving 20 records from provider A to provider B should not automatically change the employer total; discovering previously omitted required records may.

Compare the year-level group response with the reviewed membership timeline. The 2025 line 21 instructions connect a “Yes” response to the monthly group indicator and the list of other members. A current organization chart may omit a relationship that existed earlier in the reporting year.

Use the same approved source for Part II, Part III column (d), and Part IV. Record the actual effective dates behind midyear changes. If the facts are unresolved, send the question to the responsible tax or legal reviewer rather than allowing the form preparer to infer the answer from payroll labels.

The related aggregated-group worksheet can hold the evidence behind the selection without turning Part II into a separate, conflicting entity register.

For 2025, line 22 provides the Qualifying Offer Method in box A and the 98% Offer Method in box D; boxes B and C are reserved. Eligibility and actual use of the method matter. See the line 22 instructions.

Do not treat a checked box as the evidence for itself. The reviewer should be able to find the underlying analysis and explain how the choice affects the other applicable fields.

Fictional Pine Strand Company has a reviewed annual reporting population of 200 records split into batches of 150 and 50. Its authoritative transmittal accompanies the first batch. A completed entity review finds group membership during part of the year.

For the fictional method review, 196 of 200 records satisfy the reviewed offer conditions throughout the applicable periods: 196 ÷ 200 = 98%. The reviewer also confirms every other requirement. That arithmetic alone, or a 98% enrollment rate, would not establish eligibility.

Compare the final Part II to its source register and inspect related fields affected by the selections. For example, actual use of the 98% Offer Method affects the obligation to complete the Part III full-time count. Keep that field review tied to the documented method decision.

Record the output version, actual reviewer, count reconciliation, entity determination, and method evidence. If a supporting population or method changes, revisit the affected selections before release.

Use the downloadable checklist to make approval concrete. Each field should have a source reference and a clear reviewer conclusion. An unexplained checkbox is an open question even when the software accepts it.