How Can I Get Help with 1095C Instructions?


I need clarity on a few of the codes, and also need guidance as to which situation would be applicable to which code. I have already downloaded the instruction forms, but still need clarity.

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Bevelyn Rivera, SHRM-CP, PHR

What is the code I use on 1095C for employees who carry Medicare.

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I am filling out 1095-C forms for my employer – do I need to complete a 1095-C form for an employee that worked one day in the whole year? or an employee that worked less than 130 hours in a month then quit the job?

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carolyn fleetwood

What do you use on 1095C – row 16 if employee is not offered coverage because they are already on their spouses coverage with the same company? i.e. husband and wife both work and husband is dependant on wife’s coverage (or visaversa)

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Our company has a 30 day waiting period after full time status before health insurance becomes effective. What code should I use for that month. I do not see one that fits the 30 day waiting period description.

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So that is the two month or less coverage gap exemption. Only need to fill it in if there is a full month or greater. You can only take that exemption for one gap a year.

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For line 16 on the 1095-C forms, what code do you use if the employee was offered qualifying coverage but declined to enroll?

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page 10 – 11: https://www.irs.gov/pub/irs-pdf/i109495c.pdf

If i’m reading it right, you fill out 14 and then follow the directions for 15 and 16, this results in you not needing to fill out line 16. Given this is tax stuff, you’ll always want to double check and check with a professional tax person or at least verify yourself in the instructions.

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You will have to use any of the 3 Safe Harbor Codes for declination of Coverage. 2F, 2G, or 2H. Depends which one your company used to determine affordability.

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When would code 1I be used on line 14?

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I think that one is if the employer had transition relief and didn’t need to offer coverage, and in fact did not offer coverage.

From the instructions: https://www.irs.gov/instructions/i109495c/ar01.html

1I. Qualifying Offer Transition Relief 2015: Employee (and spouse or dependents) received no offer of coverage; received an offer that is not a qualifying offer; or received a qualifying offer for less than 12 months.

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Do you enter “1A” on line 14 for every employee if insurance is offered at $0 cost for employee only and minimum cost to spouse and dependents, even if an employee is single? We offer the same coverage to all employees ;however, they may not have a spouse or dependents.

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Good question. I want to tell you that I understand the difference between “1A” and “1E” or that “1B” implies that you refused coverage to dependents and spouse. But truth be told, it’s not that clear.

I would ask an accountant, barring this, I would feel that “1A” implied that you had done your job as an employer and offered coverage to everyone you could. I think the other specific answers are if you can offer coverage to another family member and don’t or if you don’t offering MEC at the right cost ratios.

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Line 22 on form 1094-C. Can all boxes be checked if we quality for all? We offer 100% of our emp. and families medical insurance after a 60 day waiting period and have an HRA in place that covers their deductibles. The employee contribution to the premium is based off the deductible amount which works out to be a contribution of 1/2 of the deductible amount (750/yr which = 21% of the single premium/yr. and 0 to the HRA (emp +families/spouses contribute 1500/yr total and 0 contribution to the HRA). If we check all the boxes do we use 1A in section 14?
Another question is Part III on 1095C. Our plan is not self insured but fully insured. Do I need to fill in the spouses and each dependent insured on their plan?
Last question, although we offer every employee insurance, not all of them enroll in our plan. Some enroll on their spouses or parents plans. Do I need to provide them with the 1095 C? If so do I use code 2C if they are not enrolled on our plan, but it is offered?

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We don’t have the answers to these questions, we encourage our readers to answer (and or hope that you will post the correct answers when you find them).

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WHAT IS THE DIFFERENCE BETWEEN LINE 14A AND LINE 14B OF THE CODES TO BE USED FOR FORM 1095 C?

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Do you mean the part about minimum essential coverage versus minimum value? For Line 14 of 1095-C:

In 1A (AKA 14A) you are saying if a qualifying offer was made. That is that you offered minimum essential coverage, providing minimum value, to at least employee and dependents (but also includes spouse if you offered to spouse). This is asking if that coverage was no more than 9.5% of employee only coverage for the employee’s share of the premium.

1B (AKA 14B) you are just looking at if minimum essential coverage providing minimum value was offered to the employee only.

So the first one is “did you make the offer you were supposed to make of offering a family plan to employee and tax dependents (and spouse if you choose”, the second one is only concerned with employee only coverage.

http://www.irs.gov/instructions/i109495c/ar01.html#d0e655

ps. Sometimes IRS forms ask you similar questions more than once. Part of this is because you need to have specific numbers (or answers) on specific lines for upcoming calculations.

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