Instructions For Forms 1094-C And 1095-C - 2017 Page 2

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Reporting by Employers That
(Lines 17–22), later. Form 1095-C may be used only if the
individual identified on line 1 has an SSN.
Sponsor Self-Insured Health Plans
Substitute Statements to Recipients
An employer that offers health coverage through a self-insured
health plan must report information about each individual
If you are not using the official IRS form to furnish statements to
enrolled in such coverage. For an employer that is an ALE
recipients, see Pub. 5223, General Rules and Specifications for
Member, this information must be reported on Form 1095-C,
Affordable Care Act Substitute Forms 1095-A, 1094-B, 1095-B,
Part III, for any employee who is enrolled in coverage (and any
1094-C, and 1095-C, which explains the requirements for format
spouse or dependent of that employee). See below for the
and content of substitute statements to recipients. You may
option to file Form 1094-B and Form 1095-B, rather than Form
develop them yourself or buy them from a private printer.
1094-C and Form 1095-C, to report coverage of certain
Substitute statements furnished to recipients may be in portrait
non-employees.
format; however, substitute returns filed with the IRS using paper
must be printed in landscape format.
ALE Members that offer health coverage through an
Authoritative Transmittal for ALE
employer-sponsored self-insured health plan must complete
Form 1095-C, Parts I, II, and III, for any employee who enrolls in
Members Filing Multiple Forms 1094-C
the health coverage, whether or not the employee is a full-time
A Form 1094-C must be filed when an ALE Member files one or
employee for any month of the calendar year.
more Forms 1095-C. An ALE Member may choose to file
multiple Forms 1094-C, each accompanied by Forms 1095-C for
For full-time employees enrolled in an ALE Member’s
a portion of its employees, provided that a Form 1095-C is filed
self-insured coverage, including an employee who was a
for each employee for whom the ALE Member is required to file.
full-time employee for at least one month of the calendar year,
If an ALE Member files more than one Form 1094-C, one (and
the ALE Member must complete Form 1095-C, Part II, according
only one) Form 1094-C filed by the ALE Member must be
to the generally applicable instructions, and should not enter
identified on line 19, Part I as the Authoritative Transmittal, and,
code 1G on line 14 for any month. For an employee enrolled in
on the Authoritative Transmittal, the ALE Member must report
an ALE Member’s self-insured coverage who is not a full-time
certain aggregate data for all full-time employees and all
employee for any month of the calendar year (meaning that for
employees, as applicable, of the ALE Member.
all 12 calendar months the employee was not a full-time
Example 1. Employer A, an ALE Member, files a single
employee), for Form 1095-C, Part II, the ALE Member must
Form 1094-C, attaching Forms 1095-C for each of its 100
enter code 1G on line 14 in the “All 12 Months” column or in the
full-time employees. This Form 1094-C should be identified as
separate monthly boxes for all 12 calendar months, and the ALE
the Authoritative Transmittal on line 19, and the remainder of the
Member need not complete Part II, lines 15 and 16.
form completed as indicated in the instructions for line 19, later.
An employer that offers employer-sponsored self-insured
Example 2. Employer B, an ALE Member, files two Forms
health coverage but is not an ALE Member should not file Forms
1094-C, one for each of its two operating divisions, Division X
1094-C and 1095-C, but should instead file Forms 1094-B and
and Division Y. (Division X and Division Y are units of the same
1095-B to report information for employees who enrolled in the
ALE Member, and thus both report under the same employer
employer-sponsored self-insured health coverage.
identification number (EIN); they are not members of an
Aggregated ALE Group.) Attached to one Form 1094-C are
Note. If an ALE Member is offering health coverage to
Forms 1095-C for the 200 full-time employees of Division X, and
employees other than under a self-insured plan, such as through
attached to the other Form 1094-C are Forms 1095-C for the
an insured health plan or a multiemployer health plan, the issuer
1,000 full-time employees of Division Y. One of these Forms
of the insurance or the sponsor of the plan providing the
1094-C should be identified as the Authoritative Transmittal on
coverage is required to furnish the information about their health
line 19, and should include aggregate employer-level data for all
coverage to any enrolled employees, and the ALE Member
1,200 full-time employees of Employer B as well as the total
should not complete Form 1095-C, Part III, for those employees.
number of employees of Employer B, as applicable, as required
in Parts II, III, and IV of Form 1094-C. The other Form 1094-C
Reporting of Enrollment Information
should not be identified as the Authoritative Transmittal on
line 19, should report on line 18 only the number of Forms
for Non-Employees: Option
1095-C that are attached to that Form 1094-C, and should leave
To Use Forms 1094-B and 1095-B
the remaining sections of the form blank as indicated in the
instructions for line 19, later.
ALE Members that offer employer-sponsored self-insured health
coverage to non-employees who enroll in the coverage may use
Note. Each ALE Member must file its own Forms 1094-C and
Forms 1094-B and 1095-B, rather than Form 1095-C, Part III, to
1095-C under its own separate EIN, even if the ALE Member is
report coverage for those individuals and other family members.
part of an Aggregated ALE Group. No Authoritative Transmittal
For this purpose, a non-employee includes, for example, a
should be filed for an Aggregated ALE Group.
non-employee director, an individual who was a retired
employee during the entire year, or a non-employee COBRA
Example 3. Assume that Employer A from Example 1 is a
beneficiary, including a former employee who terminated
member of the same Aggregated ALE Group as Employer B
employment during a previous year.
from Example 2. Accordingly, Employer A and Employer B are
separate ALE Members filing under separate EINs. Forms
For information on reporting for non-employees enrolled in an
1094-C should be filed in the same manner indicated in
employer-sponsored self-insured health plan using Forms
Examples 1 and 2. Employer A should include only information
1094-B and 1095-B, see the instructions for those forms.
about employees of Employer A in its Authoritative Transmittal,
and Employer B should include only information about
employees of Employer B in its Authoritative Transmittal. No
For ALE Members that choose to use Form 1095-C to report
Authoritative Transmittal should be filed for the Aggregated ALE
coverage information for non-employees enrolled in an
Group reporting combined data for employees of both Employer
employer-sponsored self-insured health plan, see the specific
A and Employer B.
instructions for Form 1095-C, Part III—Covered Individuals
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Instructions for Forms 1094-C and 1095-C (2017)

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