Instructions For Forms 1094-C And 1095-C - 2017 (Page 8 of 17) in pdf

respect to the employee. Employer may use the alternative

qualifies as a Limited Non-Assessment Period). Employer files a

method of completing Form 1095-C under the Qualifying Offer

Form 1095-C for each of the 300 employees (excluding the 25

Method for this Employee. However, Employer may not use the

employees that it identified as not possibly being full-time

alternative method of furnishing Form 1095-C to Employee

employees). Employer may use the 98% Offer Method because

under the Qualifying Offer Method because Employee did not

it makes an affordable offer of coverage that provides minimum

receive a Qualifying Offer for all 12 months of the calendar year.

value to at least 98% of the employees for whom Employer files

a Form 1095-C. Using this method, Employer does not identify

Alternative Method of Furnishing Form 1095-C to

whether each of the 300 employees is a full-time employee.

Employees under the Qualifying Offer Method. An ALE

However, Employer must still file a Form 1095-C for all of its

Member that is eligible to use the Qualifying Offer Method may

full-time employees. Employer chooses to file a Form 1095-C on

use the alternative method of furnishing Form 1095-C only for a

behalf of all 300 employees, including the five employees to

full-time employee who: (1) received a Qualifying Offer for all 12

whom it did not offer coverage, because if one or more of those

months of the calendar year, and (2) did not enroll in

employees was, in fact, a full-time employee for one or more

employer-sponsored self-insured coverage. For such an

months of the calendar year, Employer would be required to

employee, an ALE Member meets its obligation to furnish a

have filed a Form 1095-C on behalf of those employees.

Form 1095-C to the employee if it furnishes the employee a

statement containing the following information.

Note. If an ALE member uses the 98% offer method, it is not

Employer/ALE Member name, address, and EIN.

required to complete the “Section 4980H Full-Time Employee

Contact name and telephone number at which the employee

Count for ALE Member” in Part III, column (b).

may receive information about the offer of coverage and the

information on the Form 1095-C filed with the IRS for that

Part III—ALE Member Information—Monthly

employee.

(Lines 23–35)

Notification that, for all 12 months of the calendar year, the

employee and his or her spouse and dependents, if any,

Column (a) Minimum Essential Coverage Offer Indicator.

received a Qualifying Offer and therefore are not eligible for a

If the ALE Member offered minimum essential coverage to at

premium tax credit.

least 95% of its full-time employees and their dependents for the

Information directing the employee to see Pub. 974, Premium

entire calendar year, enter “X” in the “Yes” checkbox on line 23

Tax Credit (PTC), for more information on eligibility for the

for “All 12 Months” or for each of the 12 calendar months.

premium tax credit.

If the ALE Member offered minimum essential coverage to at

An ALE Member is not required to use the alternative method

least 95% of its full-time employees and their dependents only

of furnishing for an employee even if the alternative method

for certain calendar months, enter “X” in the “Yes” checkbox for

would be allowed. Instead, the ALE Member may furnish a copy

each applicable month.

of Form 1095-C as filed with the IRS (with or without the

For the months, if any, for which the ALE Member did not offer

statement described above).

minimum essential coverage to at least 95% of its full-time

As stated above, an ALE Member may not use the alternative

employees and their dependents, enter “X” in the “No” checkbox

furnishing method for a full-time employee who enrolled in

for each applicable month.

self-insured coverage. Rather, the ALE Member must furnish

If the ALE Member did not offer minimum essential coverage

Form 1095-C, including the information reporting enrollment in

to at least 95% of its full-time employees and their dependents

the coverage on Form 1095-C, Part III.

for any of the 12 months, enter “X” in the “No” checkbox for “All

12 Months” or for each of the 12 calendar months.

B. Reserved.

C. Reserved.

Note. For purposes of column (a), an employee in a Limited

D. 98% Offer Method. Check this box if the employer is

Non-Assessment Period is not counted in determining whether

eligible for and is using the 98% Offer Method. To be eligible to

minimum essential coverage was offered to at least 95% of an

use the 98% Offer Method, an employer must certify that, taking

ALE Member’s full-time employees and their dependents. For a

into account all months during which the individuals were

description of the differences between the definition of the term

employees of the ALE Member and were not in a Limited

Limited Non-Assessment Period used with respect to section

Non-Assessment Period, the ALE Member offered affordable

4980H(a) and the definition used with respect to section

health coverage providing minimum value to at least 98% of its

4980H(b), relating to whether the ALE Member offers minimum

employees for whom it is filing a Form 1095-C employee

value coverage at the end of the Limited Non-Assessment

statement, and offered minimum essential coverage to those

Period, see the

Definitions

section.

employees’ dependents. The ALE member is not required to

identify which of the employees for whom it is filing were full-time

An employee who is treated as having been offered

employees, but the ALE Member is still required, under the

health coverage for purposes of section 4980H (even

TIP

general reporting rules, to file Forms 1095-C on behalf of all its

though not actually offered) is treated as offered

full-time employees who were full-time employees for one or

minimum essential coverage for this purpose. For example, for

more months of the calendar year. To ensure compliance with

the months for which the ALE Member is eligible for

the general reporting rules, an ALE Member should confirm for

multiemployer arrangement interim guidance (if the ALE Member

any employee for whom it fails to file a Form 1095-C that the

is contributing on behalf of an employee whether or not the

employee was not a full-time employee for any month of the

employee is eligible for coverage under the multiemployer plan)

calendar year. (For this purpose, the health coverage is

with respect to an employee, that employee should be treated as

affordable if the ALE Member meets one of the section 4980H

having been offered minimum essential coverage for purposes

affordability safe harbors.)

of column (a). For different rules for purposes of reporting offers

of coverage on Form 1095-C, see the specific instructions for

Example. Employer has 325 employees. Of those 325

Form 1095-C, Part II, line 14.

employees, Employer identifies 25 employees as not possibly

being full-time employees because they are scheduled to work

For purposes of column (a), if the ALE Member offered

10 hours per week and are not eligible for additional hours. Of

minimum essential coverage to all but five of its full-time

the remaining 300 employees, 295 are offered affordable

TIP

employees and their dependents, and five is greater

minimum value coverage for all periods during which they are

than 5% of the number of full-time employees of the ALE

employed other than any applicable waiting period (which

Member, the ALE Member may report in column (a) as if it

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Instructions for Forms 1094-C and 1095-C (2017)

Instructions For Forms 1094-C And 1095-C - 2017 Page 8

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