Completing 1095-C forms can be confusing, but we’re here to make it simple with this list of common 1095-C coverage scenarios and examples.

As always, we are available to answer any questions you may have.

Common 1095-C Coverage Scenarios:

1. Full-Time Employee: Enrolled all 12 Months, qualifying offer
2. Full-Time Employee: Enrolled All 12 Months
3. Full-Time Employee: Waived Coverage All 12 Months
4. Full-Time Employee: Hired Midyear
5. Full-Time Employee: Hired Midyear, Qualifying offer
6. Part-Time Employee Becomes Full-Time Midyear 
7. Eligible Employee Elects Coverage Midyear 
8. Terminated Employee
9. *Self-Insured Only* Employee Elects COBRA Upon Termination 
10. *Self-Insured Only* Employee Terminated in Prior Year, Enrolled in COBRA All Year 
11. Employee was Enrolled in a Union-Sponsored Plan All Year

1. Full-Time Employee: Enrolled All 12 Months, qualifying offer

In this example, the employee (EE) was enrolled in a plan that provided Minimum Essential Coverage (MEC) at Minimum Value (MV). This plan was offered to the EE, the spouse and dependents.

• Line 14 – All 12 Months – Code 1A – The ALE Member made a qualifying offer in which the EE was enrolled for all 12 months.
• Line 15 – Should be left blank, because a qualifying offer was made. 
• Line 16 – Should be left blank, because EE enrolled in a plan that was a qualifying offer. 

2. Full-Time Employee: Enrolled All 12 Months

In this example, the employee (EE) was enrolled in a plan that provided Minimum Essential Coverage (MEC) at Minimum Value (MV) and provided MEC to the spouse and dependents. The EE was enrolled for the entire year.

• Line 14 – All 12 Months – Code 1E – MEC providing MV offered to EE and MEC was offered to the spouse and dependents. 
• Line 15 – All 12 Months – The EEs’ monthly share of the lowest-cost, self-only coverage offered needs to be populated for the months that the EE elected coverage.
• Line 16 –All 12 Months – Code 2C – EE elected coverage for all 12 months.

3. Full-Time Employee: Waived Coverage All 12 Months

In this example, the employee (EE) was offered coverage that provided Minimum Essential Coverage (MEC) at Minimum Value (MV) and provided MEC to spouse and dependents. The EE waived coverage for the entire year. 

• Line 14 –All 12 Months – Code 1E – MEC providing MV offered to EE, and MEC offered to spouse, children. EE waived coverage.
• Line 15 – All 12 Months – The EEs’ monthly share of the lowest-cost, self-only coverage offered needs to be populated for the months that the EE was offered coverage.
  • Even though coverage was waived, this has to be listed, because 1A or 1H were not used on Line 14. 
• Line 16 – Can be left blank, because coverage was waived.
  • This can be left blank unless another safe harbor applies (ie: 2G – The coverage that was offered is affordable based on the federal poverty line safe harbor).

4. Full-Time Employee: Hired Midyear

In this example, the employee (EE) was hired as a full-time employee (FTE) on April 10^th and is eligible for coverage on the first of the month after the Limited Non-Assessment Period (LNAP) of 30 days (June 1^st). The coverage that is offered provides Minimum Essential Coverage (MEC) at Minimum Value (MV) to the EE and provides MEC to spouse and dependents.

• Line 14 
  • Jan-May – Code 1H – EE was not hired or was in a Limited Non-Assessment Period (LNAP); therefore, was not offered coverage. 
  • June-Dec – Code 1E –   MEC providing MV was offered to EE, and MEC offered to spouse and dependents. EE elected coverage for these months. 
• Line 15 
  • Jan-May – Should be left blank, because coverage was not offered during these months. 
  • June-Dec – The EEs’ monthly share of the lowest-cost, self-only coverage offered needs to be populated for the months that the EE elected coverage.
• Line 16 
  • Jan-Mar – Code 2A – EE was not yet hired.
  • Apr-May – Code 2D – EE was in LNAP.
  • June-Dec – Code 2C – EE was enrolled in the offered coverage.

5. Full-Time Employee: Hired Midyear, Qualifying offer

In this example, the employee (EE) was hired as a full-time employee (FTE) on May 14^th and is eligible and enrolled in coverage on the first of the month after the limited non assessment period of 60 days (August 1^st). The coverage that is offered provides Minimum Essential Coverage (MEC) at Minimum Value (MV) to the EE, spouse, and dependents. 

• Line 14 
  • Jan-July – Code 1H – EE was not hired or was in a LNAP; therefore, was not eligible for coverage. 
  • Aug-Dec – Code 1A – The ALE Member made a qualifying offer in which the EE was enrolled for these months. 
• Line 15 – Should be left blank. 
• Line 16 
  • Jan-Apr – Code 2A – EE was not yet hired.
  • May-July – Code 2D – EE was in LNAP.
  • July-Dec – Should be left blank, because EE was enrolled in a plan that was a qualifying offer. 

6. Part-Time Employee Becomes Full-Time Midyear 

In this example, the employee (EE) was part time then promoted to full-time on February 4^th. The employee is eligible for coverage on the first of the month after the Limited Non-Assessment Period (LNAP) of 30 days (May 1^st).  The coverage that is offered provides MEC at MV to the EE and provides MEC to spouse and dependents.

• Line 14 
  • Jan-Apr – Code 1H – EE was PT or was in a LNAP; therefore, was not eligible for coverage. 
  • May-Dec – Code 1E – MEC providing MV was offered to EE, and MEC offered to spouse and dependents. EE elected coverage for these months. 
• Line 15 
  • Jan-Apr– Should be left blank, because coverage was not offered during these months. 
  • May-Dec – The EEs’ monthly share of the lowest-cost, self-only coverage offered needs to be populated for the months that the EE elected coverage.
• Line 16 
  • Jan-Mar – Code 2B – EE was PT; therefore, not eligible for coverage. 
  • Apr – Code 2D – EE was in LNAP.
  • May-Dec – Code 2C – EE was enrolled in the offered coverage.

7. Eligible Employee Elects Coverage Midyear 

In this example, the employee (EE) waived coverage during the yearly enrollment period. This employee got married in July, which is a Qualifying Life Event (QLE), and chose to enroll herself and her husband in the plan effective August 1.  The coverage that is offered provides Minimum Essential Coverage (MEC) at Minimum Value (MV) to the EE, provides MEC to spouse and dependents, and is affordable based on the Federal Poverty Line (FPL) safe harbor. 

• Line 14 
  • Jan-June – Code 1H – EE waived coverage; therefore, was not offered coverage. 
  • July-Dec – Code 1E – MEC providing MV offered to EE and MEC was offered to the spouse and dependents. 
• Line 15 
  • Jan-June– Should be left blank, because coverage was not offered during these months. 
  • July-Dec – The EEs’ monthly share of the lowest-cost, self-only coverage offered needs to be populated for the months that the EE elected coverage.
• Line 16 
  • Jan-June – Code 2G – The coverage offered to the employee is affordable based on the FPL safe harbor.
  • July-Dec – Code 2C – EE was enrolled in the offered coverage.

8. Terminated Employee

In this example, the employee (EE) was enrolled starting at the beginning of the year, and was terminated from the company on April 10^th. The coverage also ends on the date of termination. The coverage that was offered provides Minimum Essential Coverage (MEC) at Minimum Value (MV) to the EE and provides MEC to spouse and dependents. 

* * Please note: Since the employee was terminated in the middle of April, they will not have a coverage code on Line 14 or 16, because they were not covered for all of the days of the month. **

• Line 14 
  • Jan-Mar – Code 1E – MEC providing MV offered to EE and MEC was offered to the spouse and dependents.
  • Apr-Dec – Code 1H – EE was terminated which ended the offer of coverage. 
• Line 15 
  • Jan-Mar – The EEs’ monthly share of the lowest-cost, self-only coverage offered needs to be populated for the months that the EE elected coverage.
  • Apr–Dec – Should be left blank, because coverage was not offered during these months.
• Line 16 
  • Jan-Mar – Code 2C – EE was enrolled in the offered coverage.
  • Apr–Dec – Code 2A – The employer did not employ this person during these months.

9. *Self-Insured Only* Employee Elects COBRA Upon Termination 

In this example, the employee (EE) was enrolled in employer-sponsored self-insured coverage that offered Minimum Essential Coverage (MEC) at Minimum Value (MV) to the EE and MEC to the spouse and dependents. The EE was terminated in October and was offered COBRA continuation coverage. The employee enrolled in this coverage in November and December.

• Part II, Lines 14-16 – This example will be the same as the one used for example #8: Terminated Employee.
• Part III – Complete for each covered individual that was enrolled in coverage for at least one month.
  • Part III is where to indicate the months that the employee and/or spouse and dependents are enrolled in coverage. Since the EE was enrolled in the employer sponsored plan for Jan-Oct and elected COBRA for Nov-Dec, the EE was covered for all 12 months. 

10. *Self-Insured Only* Employee Terminated in Prior Year, Enrolled in COBRA All Year 

In this example, the employee was terminated in the last tax year and elected COBRA. This employee has chosen to remain enrolled in COBRA for this entire tax year, for himself and 2 dependents.

• Line 14 – All 12 Months – Code 1G – The employer offered self-insured coverage to an employee who was not full time at any point in the year.  
  • Please Note: When Code 1G is used, it must be specified for all 12 months or not at all. 
• Line 15 – Should be left blank.   
• Line 16 – Should be left blank.
• Part III – Complete for each covered individual that was enrolled in coverage for at least one month.

11. Employee was Enrolled in a Union-Sponsored Plan All Year 

In this example, the employee (EE) was enrolled in a union-sponsored medical plan for all 12 months of the year.

• Line 14 – All 12 Months – Code 1H – The employee was eligible for a multi-employer (union) plan; therefore, no coverage was offered from the employer. 
• Line 15 – Should be left blank.
• Line 16 – All 12 Months – Code 2E – The EE was enrolled in a union-sponsored plan, so the employer is eligible for the multi-employer interim relief rule. 

For more information, please contact BoomTax Support:

Have you ever asked yourself: “Do I have to complete my ACA filings for previous tax years?” The answer is YES. There is no statute of limitations in assessing Employer Shared Responsibility Payment (ESRP).

The IRS published a Memo on February 24, 2020 regarding the statute of limitations for assessment of an ESRP under Section 4980H. The Memo makes it quite clear that there is none in regards to assessment of ESRP.

The Office of Chief Counsel stated that it is not possible for the IRS to determine the ESRP solely using Forms 1094-C and 1095-C. Subsequently, the filing of these returns does not fall under the statue of limitations under Section 6501 (a).

Employer Shared Responsibility

According to the IRS, “anything that an ALE is liable to pay under section 4980H is called the Employer Shared Responsibility Payment (“ESRP”).” The IRS determines the ESRP by collecting information from the ALEs and their FTEs.

If you are an ALE and do not offer affordable health coverage to at least 95% of your full-time employees, you may be subject to one of two employer shared responsibility payments.

An ALE member will owe the first type of payment if:

• ALE member failed to offer Minimum Essential Coverage (MEC) to at least 95% of its full-time employees (FTEs) and their dependents.
• AND if at least one FTE receives a premium tax credit for purchasing coverage through the Marketplace.

If an ALE member fails to offer MEC that is affordable to their FTEs, the ALE member may be subject to the second type of ESRP.

An ALE member could owe the second type of payment if:

• The MEC the employer offers to the employee is not affordable.
• The MEC the employer offers does not provide minimum value.
• OR, The employee is not one of the ‘at least 95% of employees’ that is offered MEC.

Part-time and full-time equivalent employees do not factor in to the calculation of ESRPs.

Please find additional information on related topics below:
– What is Employer Shared Responsibility?
– What is IRS Letter 226-J?
For more information, please contact BoomTax Support: