1095-C Master Guide

1095-C forms are insane. We are with you on that one. Many of the resources out there to “help” us “simplify” the process are not quite doing the trick, so I’m laying out everything you need to know about 1095-C filing. More to come about the other pesky forms.

Our faces when we read the 1095-C requirements

I’ll try to lay it out in a way that simplifies it a little.

Who fills this out?

If you have over 100 Full Time Equivalents (FTEs), you have a 1095-C form due February 28, 2016, if you’re filing on paper, or March 31, 2016, if you’re filing electronically. Between 50 and 100 employees do not have to worry about ACA reporting until 2017. Under 50 is not responsible for any ACA reporting. It is the employer’s responsibility to have these forms completed on behalf of each employee.

Which employees need a 1095-C form?

-Full-time employees (worked an average of 30 hours a week or more in 2015)

-Employees covered by a self-insured plan by the employer for one day or more in 2015 (full or part time)

Which parts do I need to fill out?

-Full-time employees must have forms with parts I and II completed, and if the employer self-insures, part III as well

-Non-full-time employees who are still covered by a self-insured plan by the employer must have forms with parts I and III completed

What do these parts require?

Part I: Completed on behalf of full-time employees, and of part-time employees covered by a self-insured plan

This portion is pretty straightforward, just the employee’s name and who their employer is.

Part II: Completed on behalf of the employee; only completed if the employee worked full-time for at least one month of 2015

This consists of three rows of information to be entered, with boxes that represent every month of the calendar year. That’s going to look a little something like this:

The nature of coverage offered is to be listed in Row 1 via a series of 9 codes. Any of these codes that apply are listed for each month, for each employee.

Row 2 is a monthly proprietary recording of the cost of the least expensive coverage offered to the employee, as long as it met minimum actuarial value and affordability requirements.

Row 3 refers to whether the employee was covered under an employer plan, whether the employer qualified for an exception from the employer mandate and whether the employer is relying on one (or more) of three safe harbors in assessing the affordability of its coverage. This is identified with nine code options.

Part III: Filled out on behalf of any employee using self-insured coverage, full- and part-time

The employee lists the dependents on their plan along with their Social Security Numbers. This is also meant to establish the plan’s compliance with the individual mandate put forth by the ACA.

That’s it for 1095-C.

In part 2, we’ll discuss the 1094-C forms and how to report non-employees enrolled on an employer-sponsored, self-insured health plan.