Identify Covered Individuals and Gather Information for Form 1095-C

For self-insured plans, you’ll need to identify covered individuals (employee, spouse, and their dependents) and their social security numbers. A date of birth will work in lieu of a social security number if you’ve made a reasonable attempt to gather SSNs for all non-employee covered individuals.

Keep in mind that self-insured coverage is defined as coverage where the employer assumes the financial risk for providing health care benefits to its employees. This coverage is rare for small businesses since it is typically costly.

Form 1095-C lines 17-22 must be completed by an employer offering self-insured health coverage for any individual who was an employee for one or more calendar months of the year, whether full-time or non-full-time and who enrolled in the coverage.

According to the IRS:

All employee family members that are covered individuals through the employee’s enrollment (for example, because the employee elected family coverage) must be included on the same form as the employee (or individual to whom the offer was made). For example, if the employee is offered family coverage by his or her employer under a self-insured health plan and enrolls in the family coverage, the employee and the employee’s family members that are covered under the plan must all be reported on Form 1095-C.

If two or more employees employed by the same employer are spouses or employee and dependent, and one employee enrolled in a coverage option under the plan that also covered the other employee(s) (for example, one employee spouse enrolled in family coverage that provided coverage to the other employee spouse and their employee dependent child), the enrollment information should be reflected only on the Form 1095-C for the employee who enrolled in the coverage (but would report the other employee family members as covered individuals).

Coverage of Non-Employee.   This part may be completed by an employer offering self-insured health coverage for any other individual who enrolled in the coverage under the plan for one or more calendar months of the year but was not an employee for any calendar month of the year, such as a non-employee director, a retired employee who retired in a previous year, a terminated employee receiving COBRA coverage who terminated employment during a previous year, and a non-employee COBRA beneficiary (but not including an individual who obtained coverage through the employee’s enrollment, such as a spouse or dependent obtaining coverage when an employee elects family coverage). If the Form 1095-C is used with respect to an individual who was not an employee for any month of the calendar year, Part II must be completed by using Code 1G in the “All 12 Months” box or the box for each month of the calendar year.

If you offer self-insured coverage, we strongly recommend you gather covered individual data now as it can be difficult to gather all information for all employees in a timely manner.

For more information on ACA information returns filings, check out the IRS website or view our other blog posts linked below:

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