1. US Affordable Care Act Year-End Processing Guide
  2. Who Must File Forms 1094-C and 1095-C

Who Must File Forms 1094-C and 1095-C

Applicable Large Employers, generally employers with 50 or more full-time employees (including full-time equivalent employees) in the previous year, must file Form 1095-C for each employee who was full-time for any month of the calender year. Generally, the employer is required to furnish a copy of the Form 1095-C (or a substitute form) to the employee.

Each employer has their own reporting obligation related to the health coverage that they offered (or did not offer) to each of their full-time employees. Generally, an employer is subject to employer shared responsibility provisions under section 4980H when they have 50 or more full-time employees, including full-time equivalent employees, during the prior calendar year.

An employer that offers health coverage through an employer-sponsored self-insured health plan must complete Form 1095-C, Parts I, II, and III, for any employee who enrolls in the health coverage, irrespective of whether the employee is a full-time employee for any month of the calendar year. If the employee who enrolled in self-insured coverage is a full-time employee for any month of the calendar year, the employer must complete Part II (in addition to Parts I and III). If the employee who enrolled is not a full-time employee, for any month of the calendar year (which means that for all 12 calendar months the employee was not a full-time employee), the employer must complete Form 1095-C, Parts I and III and on Part II, must enter code 1G on line 14 in the “All 12 Months" column or in each separate monthly box (the employer need not complete Part II, lines 15 and 16 in this case).If an employer is offering health coverage to employees other than under a self-insured plan, such as through an insured health plan or a multi-employer health plan, the issuer of the insurance or the sponsor of the plan providing the coverage is required to furnish the information about their health coverage to any enrolled employees, and the employer should not complete Form 1095-C, Part III, for those employees.An employer that offers employer-sponsored self-insured health coverage but is not an applicable large employer subject to the employer shared responsibility provisions under section 4980H, should not file Forms 1094-C and 1095-C.

You should submit Form 1095-C for:

  • Employees who were full-time for any month of the year.

  • Employees who enrolled in self-insured coverage, regardless of their full-time status.

  • COBRA participants and retirees covered under a health coverage plan.