Page 2 of 18 Fileid: … 094c&1095c/2024/a/xml/cycle03/source 16:22 - 29-Aug-2024
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
ALE Members that offer health coverage through an
employer-sponsored, self-insured health plan must complete
Form 1095-C, Parts I, II, and III, for any employee who enrolls in
the health coverage, whether or not the employee is a full-time
employee for any month of the calendar year.
For full-time employees enrolled in an ALE Member’s
self-insured coverage, including an employee who was a
full-time employee for at least 1 month of the calendar year, the
ALE Member must complete Form 1095-C, Part II, according to
the generally applicable instructions, and should not enter code
1G on line 14 for any month. For an employee enrolled in an ALE
Member’s self-insured coverage who is not a full-time employee
for any month of the calendar year (meaning that for all 12
calendar months the employee was not a full-time employee), for
Form 1095-C, Part II, the ALE Member must enter code 1G on
line 14 in the “All 12 Months” column or in the separate monthly
boxes for all 12 calendar months, and the ALE Member need not
complete Part II, lines 15 and 16.
An individual coverage HRA is a self-insured group
health plan and is therefore an eligible
employer-sponsored plan. An individual is ineligible for a
premium tax credit (PTC) for a month if the individual is covered
by an individual coverage HRA or eligible for an individual
coverage HRA that is affordable.
An employer that offers employer-sponsored, self-insured
health coverage but is not an ALE Member should not file Forms
1094-C and 1095-C, but should instead file Forms 1094-B and
1095-B to report information for employees who enrolled in the
employer-sponsored, self-insured health coverage.
Note. If an ALE Member is offering health coverage to
employees other than under a self-insured plan, such as through
an insured health plan or a multiemployer health plan, the issuer
of the insurance or the sponsor of the plan providing the
coverage is required to furnish the information about their health
coverage to any enrolled employees, and the ALE Member
should not complete Form 1095-C, Part III, for those employees.
Reporting of Enrollment Information
for Non-Employees: Option
To Use Forms 1094-B and 1095-B
ALE Members that offer employer-sponsored, self-insured
health coverage to non-employees who enroll in the coverage
may use Forms 1094-B and 1095-B, rather than Form 1095-C,
Part III, to report coverage for those individuals and other family
members. For this purpose, a non-employee includes, for
example, a non-employee director, an individual who was a
retired employee during the entire year, or a non-employee
COBRA beneficiary, including a former employee who
terminated employment during a previous year.
For information on reporting for non-employees enrolled in an
employer-sponsored, self-insured health plan using Forms
1094-B and 1095-B, see the instructions for those forms.
For ALE Members that choose to use Form 1095-C to report
coverage information for non-employees enrolled in an
employer-sponsored, self-insured health plan, see the specific
instructions for Form 1095-C,
Part III—Covered Individuals
(Lines 18–30), later. Form 1095-C may be used only if the
individual identified on line 1 has an SSN.
Substitute Statements to Recipients
If you are not using the official IRS form to furnish statements to
recipients, see Pub. 5223, General Rules and Specifications for
Affordable Care Act Substitute Forms 1095-A, 1094-B, 1095-B,
1094-C, and 1095-C, which explains the requirements for format
and content of substitute statements to recipients. You may
develop them yourself or buy them from a private printer.
Substitute statements furnished to recipients may be in portrait
format; however, substitute returns filed with the IRS using paper
must be printed in landscape format.
Authoritative Transmittal for ALE
Members Filing Multiple Forms 1094-C
A Form 1094-C must be filed when an ALE Member files one or
more Forms 1095-C. An ALE Member may choose to file
multiple Forms 1094-C, each accompanied by Forms 1095-C for
a portion of its employees, provided that a Form 1095-C is filed
for each employee for whom the ALE Member is required to file.
If an ALE Member files more than one Form 1094-C, one (and
only one) Form 1094-C filed by the ALE Member must be
identified on line 19, Part I, as the Authoritative Transmittal, and,
on the Authoritative Transmittal, the ALE Member must report
certain aggregate data for all full-time employees and all
employees, as applicable, of the ALE Member.
Example 1. Employer A, an ALE Member, files a single Form
1094-C, attaching Forms 1095-C for each of its 100 full-time
employees. This Form 1094-C should be identified as the
Authoritative Transmittal on line 19, and the remainder of the
form completed as indicated in the instructions for
line 19, later.
Example 2. Employer B, an ALE Member, files two Forms
1094-C, one for each of its two operating divisions, Division X
and Division Y. (Division X and Division Y are units of the same
ALE Member, and thus both report under the same employer
identification number (EIN); they are not members of an
Aggregated ALE Group.) Attached to one Form 1094-C are
Forms 1095-C for the 200 full-time employees of Division X, and
attached to the other Form 1094-C are Forms 1095-C for the
1,000 full-time employees of Division Y. One of these Forms
1094-C should be identified as the Authoritative Transmittal on
line 19, and should include aggregate employer-level data for all
1,200 full-time employees of Employer B as well as the total
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
should not be identified as the Authoritative Transmittal on
line 19, and should report on line 18 only the number of Forms
1095-C that are attached to that Form 1094-C, and should leave
the remaining sections of the form blank, as indicated in the
instructions for
line 19, later.
Note. Each ALE Member must file its own Forms 1094-C and
1095-C under its own separate EIN, even if the ALE Member is
part of an Aggregated ALE Group. No Authoritative Transmittal
should be filed for an Aggregated ALE Group.
Example 3. Assume that Employer A from Example 1 is a
member of the same Aggregated ALE Group as Employer B
from Example 2. Accordingly, Employer A and Employer B are
separate ALE Members filing under separate EINs. Forms
1094-C should be filed in the same manner indicated in
Examples 1 and 2. Employer A should include only information
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
Authoritative Transmittal should be filed for the Aggregated ALE
Group reporting combined data for employees of both Employer
A and Employer B.
Similar rules apply for a Governmental Unit that has
delegated its reporting responsibilities for some of its employees
to another Governmental Unit—see Designated Governmental
Entity (DGE) in the Definitions section of these instructions for
more information. In the case of a Governmental Unit that has
delegated its reporting responsibilities for some of its employees,
2
Instructions for Forms 1094-C and 1095-C (2024)