Form 1095-C

Form 1095‑C Explained: Employer‑Provided Health Insurance Offer and Coverage

Under the Affordable Care Act (ACA), large employers—generally those averaging at least 50 full‑time employees (including full‑time equivalents)—must issue Form 1095‑C each year. This IRS form tells the agency and your workforce exactly what health coverage, if any, was offered to every full‑time employee and their dependents for each month of the calendar year. The IRS uses the data to determine whether the employer owes a shared‑responsibility payment, while employees can use their copy of Form 1095‑C to:

• verify that they had minimum essential coverage, and
• confirm—or establish ineligibility for—the premium tax credit available through the Health Insurance Marketplace.

Although the form itself is not filed with an individual tax return, keeping it with year‑end tax records helps employees answer health‑coverage questions on Form 1040 quickly and accurately.

What Information Appears on ACA Form 1095‑C?

Form 1095‑C breaks its disclosure into three parts that collectively paint a month‑by‑month picture of the health coverage (or lack of coverage) an Applicable Large Employer (ALE) offered to each full‑time employee and their dependents. Key data points include:

1. Employer Details (Part I): Legal name, mailing address, and Employer Identification Number (EIN) of the ALE, plus a contact phone number employees can call with questions.
2. Employee Details (Part I): Employee’s name, address, and taxpayer identification number (generally the Social Security number) so the IRS can match an individual to the coverage offer.
3. Offer of Coverage (Part II – Lines 14‑16):
   • Which plan option—if any—was offered to the employee, spouse, and dependents for each calendar month.
   • The employee’s share of the lowest‑cost self‑only premium (Line 15), stated to the nearest cent.
   • Whether the offer satisfied affordability using one of the ACA’s three safe harbors (W‑2, Rate‑of‑Pay, or Federal Poverty Line) and other special situations, reported through Line 14‑16 codes.
4. Full‑Time Status Indicator (Part II): A month‑by‑month checkbox confirming whether the employee met the ACA’s 30‑hours‑per‑week (or 130‑hours‑per‑month) full‑time definition.
5. Covered Individuals (Part III): A roster of every person actually enrolled—employee and any dependents—with Social Security numbers (or birth dates if an SSN is unavailable) and the specific months they enjoyed coverage.
6. Minimum Essential Coverage & Minimum Value: Implicit in the codes, Form 1095‑C indicates whether the offered plan met the ACA’s minimum essential coverage (MEC) threshold and, when required, provided minimum value (MV)—i.e., covered at least 60 % of total allowed costs.

Form 1095-C is essential in determining whether the employer meets its obligations under the ACA's employer mandate, and for employees, it helps in understanding the coverage offered and their eligibility for certain tax provisions.

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1095‑B vs. 1095‑C: How the ACA Uses Each Form

Forms 1095‑B and 1095‑C are companion information returns created by the Affordable Care Act, but they flow from different reporting parties and answer different compliance questions. In short, Form 1095‑C documents the offer of coverage made by an Applicable Large Employer (ALE), while Form 1095‑B documents the existence of coverage—regardless of who provided it.

1. Form 1095‑C – Employer‑Provided Offer and Coverage
   • Who files? Employers that averaged 50 or more full‑time employees (including FTEs) in the prior calendar year—known as Applicable Large Employers.
   • Main audience: Every full‑time employee (and the IRS).
   • What it tells the IRS:
     • Whether the employer offered minimum essential, minimum‑value coverage to the employee, spouse, and dependents for each month.
     • The employee’s cost for the lowest‑priced self‑only option.
     • Safe‑harbor or transition‑relief codes that could shield the employer from an Employer Shared Responsibility Payment (ESRP).
   • Why employees keep it: To answer the health‑coverage questions on Form 1040 and to verify any Marketplace premium‑tax‑credit determinations.
2. Form 1095‑B – Health Coverage Statement
   • Who files?
     • Insurance carriers issuing fully insured group or individual plans,
     • Government programs such as Medicaid, CHIP, or TRICARE, and
     • Any employer of any size that operates a self‑insured health plan (small self‑insured employers file 1095‑B; large self‑insured employers file Part III of 1095‑C instead).
   • Main audience: Each person actually enrolled in minimum essential coverage—employee, spouse, and dependents—plus the IRS.
   • What it tells the IRS:
     • Identifying data for every covered individual (name, SSN/DOB).
     • Which months each person had minimum essential coverage.
   • Why individuals keep it: To prove continuous coverage if the individual‑mandate penalty applies at the state level (for example, in CA, DC, MA, NJ, or RI) and to reconcile any advance premium‑tax‑credit payments.

Quick recap: Form 1095‑C answers the question, “Did the large employer offer affordable, compliant coverage?” Form 1095‑B answers, “Who was actually covered, and for which months?” Depending on your circumstances you may receive one form, both, or neither, and you should retain whichever you receive with your annual tax records.

When is the deadline to submit Form 1095-C to the IRS?

Employers filing electronically must submit Form 1095-C to the IRS by Monday, March 31^st, 2025.

If filing by paper, the deadline is Friday, February 28^th, 2025.

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Frequently Asked Questions

What if an employee didn't participate in the employer's health plan?

If an employee didn't participate in the employer's health plan, this situation will still be reflected on Form 1095-C if the employer is subject to the Affordable Care Act's (ACA) employer mandate (typically employers with 50 or more full-time employees).

Here's how the information would typically be reported:

1. Part II, Line 14: The employer would use specific IRS codes to indicate the type of coverage that was offered to the employee, even if the employee declined the offer.
2. Part II, Line 15: This line might still show the employee's share of the lowest-cost monthly premium for self-only minimum essential coverage, even if the employee did not enroll.
3. Part III: If the employee did not participate in the health coverage, this section, which typically reports information about covered individuals and dependents, would likely be left blank.

Form 1095-C provides information both about the coverage that was offered and about the coverage (if any) in which the employee actually enrolled. Even if the employee declined to participate in the employer's health plan, the form still serves to document the offer of coverage, which is important for both the employer's and the employee's compliance with the ACA. It's also used by the IRS to determine the employee's eligibility for premium tax credits if they purchased coverage through the Health Insurance Marketplace.

I received Form 1095-C in the mail. What am I supposed to do with it?

Recipients should keep Form 1095-C for your records, as it provides information about the health coverage offered to you by your employer. It contains important information that may be required when you file your personal income tax return. You don't need to attach the form to your tax return, but you should retain it with your other tax documents in case you need to refer to it in the future or if you are asked for it by the Internal Revenue Service (IRS).