Form 1094-B, Transmittal of Health Coverage Information Returns
Form 1095-B, Health Coverage
Instructions for Forms 1094-B and 1095-B
Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return
Form 1095-C, Employer-Provided Health Insurance Offer and Coverage
Instructions for Forms 1094-C and 1095-C
Health insurance issuers or carriers;
Self-insured health plan sponsors;
Government agencies that administer government-sponsored health insurance programs; and
Any other entity that provides MEC.
Form 1095-C is used to report information about each employee.
An ALE that sponsors a self-insured plan will complete all sections of Form 1095-C to report the information required under both Sections 6055 and 6056. Therefore, these ALEs will be able to use a single form to report information regarding whether an employee was covered.
An ALE that provides insured coverage will also report on Form 1095-C, but will complete only the sections of Form 1095-C related to Section 6056.
A retired employee who retired in a previous year;
A terminated employee receiving COBRA coverage who terminated employment during a previous year; and
A nonemployee COBRA beneficiary.
A nonemployee does not include an individual who obtained coverage through the employee’s enrollment, such as a spouse or dependent obtaining coverage when an employee elects family coverage.
The final instructions also made the following changes and clarifications:
The Employer Identification Number (EIN) may be truncated on any statements furnished to employees or individuals, but not on any forms filed with the IRS (previously, truncation of EINs was not allowed on any forms).
When determining the total employee count for the ALE for purposes of Form 1094-C, Part III, Column (c), an ALE may now choose to use either the first or last day of the first payroll period that starts during each month, or the first or last day of each month.
All ALEs, including U.S. ALEs, should include a country code with the employee’s address in Part I of Form 1095-C.
An offer of coverage is treated as having been made to an employee’s dependents only if the offer of coverage is made to an unlimited number of dependents, regardless of the actual number of dependents (if any) an employee has during any particular calendar month.
If spouses (or employee and dependent) are employed by the same ALE, and one employee enrolled in a coverage option that also covered the other employee(s) (for example, 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 it would report the other employee family members as covered individuals).
An ALE is not required to file a Form 1095-C for an individual who, for all months of a calendar year, is either not an employee of the ALE or is in a limited non-assessment period. However, for the months in which the employee was an employee of the ALE, he or she would be included in the total employee count reported on Form 1094-C, Part III, Column (c). (Also, if the employee enrolled in self-insured employer-sponsored coverage during the limited non-assessment period, the employer must file a Form 1095-C for the employee in order to report coverage information for the year.)
For purposes of reporting, an offer to a spouse includes an offer to a spouse that is subject to a reasonable, objective condition, regardless of whether the spouse meets the condition. For example, an offer to a spouse that is available only if the spouse certifies that he or she does not have access to health coverage from another employer is treated as an offer of coverage to the spouse for reporting purposes. (Note that this treatment is for reporting purposes only, and generally will not affect the spouse’s eligibility for the premium tax credit if the spouse did not meet the condition and therefore did not have an actual offer of coverage.)