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ERIC Comment Letter to IRS on Draft Forms 1094-C and 1095-C and Corresponding Instruction (PDF)
The ERISA Industry Committee [ERIC] 
[Opinion] Oct. 20, 2014
9 pages. "Simplified reporting and/or additional time should be provided for large companies to gather and report the information on Forms 1094-C and 1095-C.... Treasury should clarify when the company is required to report covered individuals, employees, and/or non-employees ... Treasury should clarify that employees in the initial measurement period (and related administrative period) should not be included in the reporting.... Treasury should not require companies to provide information about their total number of employees ... Additional guidance is needed regarding the 'Qualifying Offer' Method.... Treasury should not require companies to identify all of the members of an Aggregated ALE Group .... The rules for reporting employees working for more than one ALE within an Aggregated ALE Group should be simplified."
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