Zorro provides the data needed for ACA Forms 1094-C and 1095-C in a comprehensive file called the ACA Compliance Report. This report consolidates all data required in order to prepare reports, including employee information, monthly eligibility, and insurance offering data required to determine monthly affordability and coverage. Insurance offering data includes the employee’s benchmark plan per month (with ICHRA, the lowest-cost-silver-plan), allowance, and actual plan selections and costs.
Zorro does not house (and therefore cannot provide) data around employees’ monthly compensation. This would typically come from your HRIS or payroll system, and the two data sources should be combined by your ACA reporting vendor or partner who will help you prepare and submit the final reports.
Employee & Company Identifying Information
This section contains demographic information about the employee.
Columns A–M: These columns contain employee identifying details required for Form 1095-C, Part I. Includes:
Columns A–B: Employee first and last name
Column C: Employee SSN
Columns D–F: Address, state, and ZIP code
Columns G–H: Email and phone number (for reference only)
Column I: Employee ID
Columns J–K: Employee age (as of January 1 and plan start)
Columns L–M: Company and employee plan start month
Employment Status (Monthly)
This section includes a monthly indication of whether the employee was employed. Note that the data appears as it was provided to Zorro. Since Zorro is not the employment system of records, it’s important to validate and cross reference this with your HRIS or payroll system.
Columns N–Z: This section reflects employment status by month and supports offer-of-coverage determinations.
Column N: Header for employment indicator columns
Columns O–Z: Monthly employment status (January–December)
Benefit Eligibility (Monthly)
This section helps determine whether an employee was eligible and should have been made an offer of coverage for ACA coding purposes.
Columns AA–AM: This section shows when an employee was eligible for the ICHRA based on your company’s waiting period and eligibility rules.
Column AA: Header for eligibility indicator column
Columns AB–AM: Monthly eligibility status (January–December)
Employee Location Data (Benchmark Plan Inputs)
This section includes the inputs required in order to deduce the employee’s monthly benchmark plan used for affordability calculations. With ICHRA, the benchmark plan is the Lowest Cost Silver Plan (LCSP) offered to the employee. This is determined by the employee’s residence, so it must be calculated per each month (since employees can move, and their LCSP could therefore change). These columns are not directly required for your report creation. They are included in Zorro’s data to show how the LCSP benchmark plan was derived.
ZIP Code (Monthly)
Columns AN–AZ
Column AN: Header for ZIP code columns
Columns AO–AZ: Monthly ZIP code values
County (Monthly)
Columns BA–BM
Column BA: Header for county columns
Columns BB–BM: Monthly county values
FIPS Code (Monthly)
Columns BN–BZ
Column BN: Header for FIPS code columns
Columns BO–BZ: Monthly FIPS values
Benchmark & Affordability Data
The LCSP per each month based on the employee’s data in the prior section. This is the benchmark plan used for ACA affordability testing.
Columns CA–CM - LCSP
Column CA: Header for LCSP columns
Columns CB–CM: Monthly LCSP premium for employee-only coverage (January–December)
Columns CN–CZ - Employer Contribution
Column CN: Header for employer allowance columns
Columns CO–CZ: Monthly allowance values for employee-only coverage. This reflects the amount the employer would contribute regardless of the plan the employee selected.
Columns DA–DM - Employee Required Contribution
Column DA: Header for employee-only required contribution
Columns DB–DM: Monthly employee out-of-pocket amount toward the LCSP. This is the amount that should be used with the yearly affordability percentage against the appropriate affordability methodology (Federal Poverty Line, Rate of Pay, W-2, or actual income) when your ACA vendor codes and prepares the reports.
Coverage Months Indicator
This section supports Line 16 coding and full-year vs partial-year determinations.
Columns DN–DZ
Column DN: Header for coverage months indicator columns
Columns DO–DZ: Monthly coverage indicators (January–December)
Actual Plan Enrollment & Contributions
This section reflects the plan an employee actually enrolled in, if applicable. These fields reflect actual enrollment, which may differ from the benchmark affordability calculation.
Actual Monthly Premium
Columns EA–EM
Column EA: Header for actual plan premium columns
Columns EB–EM: Actual monthly premium amounts based on the plan the employee enrolled in
Actual Employer Contribution
Columns EN–EZ
Column EN: Header for actual employer contribution columns
Columns EO–EZ: Monthly employer contribution amounts
Actual Employee Contribution
Columns FA–FM
Column FA: Header for actual employee contribution columns
Columns FB–FM: Monthly employee contribution amounts
Covered Individuals (Dependents)
This section supports Form 1095-C, Part III, when applicable.
Columns FN–GB. Includes:
Column FN: Covered individual indicator
Column FO: Covered individual type (employee or dependent)
Columns FP–FQ: Dependent first and last name
Column FR: Dependent SSN
Column FS: Date of birth
Column FT: Coverage indicator
Columns FU–GB: Monthly coverage status (January–December)
Best Practices Before Filing
Validate employment and termination dates against your HRIS
Confirm eligibility and offer months align with plan rules
Apply a consistent affordability methodology
Review partial-year employees carefully
For questions about how data is generated in Zorro, contact your Zorro Customer Success Manager. For filing and coding guidance, consult your ACA reporting vendor or tax advisor.