Employer Guide & Glossary
THREE COMMON 1095-C ERRORS
FORMs 1095-C are specific to each individual employee of an APPLICABLE LARGE EMPLOYER [ALE] with full-time status or enrolled in a self-insured plan for at least one month of the reporting tax year.
PART II of FORM 1095-C identifies for each month whether an offer of coverage was made to the employee, the employee’s own contribution amount [for self-only coverage], and an IRS CODE denoting this offer and coverage status of the employee.
FORMs 1095-C are completed and made available to employees by the ALE, who then also submits
them to the IRS along with the transmittal form. If an employee has full-time status for at
least one month, all months must be coded on the form.
Three common FORM 1095-C pitfalls and questions are addressed below.
- SHORT-TERM EMPLOYEES working 30 or more hours per week are considered full-time employees under the ACA, even if they only work 3 or 4 months and however classified (for example, short-term, temporary, interns, or co-op employees). They are NOT considered VARIABLE HOUR EMPLOYEES.
- SELF-EMPLOYED INDIVIDUALS are NOT considered W-2 employees for ACA employer mandate purposes, and no FORM 1095-C is required. SELF-EMPLOYED STATUS includes sole proprietors, partners in a partnership, and 2% S corporation shareholders.
If you have questions regarding IRS CODING and the completion of FORM 1095-C or any other aspect of ACA reporting & compliance, please contact BENEFITSCAPE, the leading ACA specialist.
BENEFITSCAPE provides best-in-class ACA services, including intelligent, system-agnostic ACA_RegTech, to 1000s of employers of all sizes, in all sectors, and on all major HCMs.