The documents below are meant to be examples of what you should expect to see for some of the most common employee situations. Each employee situation is different, so you may have employees whose 1095-C forms do not match any of the example below. To verify that those forms are correct, use the Line 14 and Line 16 guides above.


Full-time, insured all year

If an employee’s status and coverage has remained constant throughout the year, columns 14, 15, and 16 will remain unchanged. In this case, you will only find one entry for each in the “All 12 Months” line, rather than an entry for each individual month.



In the above example, the employee was offered insurance for themselves, dependents, and their spouse (2E); the offer was accepted (2C); and their monthly required contribution remained unchanged throughout the year.


It is also possible that some of the categories will remain the same all year, while others will change. This will frequently happen if your plan’s renewal date is mid-year, in which case lines 14 and 16 may remain unchanged, while the Employee Required Contribution changes:



Mid-year Hire (waiting Period)

Employees hired mid-year are often required to go through a waiting period before they become eligible for health benefits. In this case, their 1095-C forms will show:

  1. During the period of time they were not employed, the value in line 14 will be 1H (no offer of coverage), line 15 will be blank, and line 16 will be 2A (not employed).
  2. Once they are hired, line 16 will be changed to indicate they are in a waiting period (2D).
  3. When they become eligible for insurance, line 14 will change to indicate that an offer was given, line 15 will reflect the price of the lowest-cost single only coverage option, and line 16 will indicate whether they accepted the insurance.



Full-time to Variable Hour

When an employee moves from full-time to variable hour, they may become ineligible for health insurance coverage. In this case, they will have the option to continue receiving insurance through COBRA coverage.


COBRA Elected

If the employee elects COBRA coverage as a result of a reduction in hours, lines 14 and 16 should remain unchanged, but the Employee Required Contribution will change to reflect the new COBRA costs.



In the example above, the employee transitioned to COBRA coverage in May, as evident by pricing increase.


COBRA Waived

If the employee waives COBRA coverage, line 16 will be updated to show they were no longer eligible for employer-based insurance coverage, because they were not employed full-time. And line 15 is updated to show the new pricing under COBRA.



Note that line 14 does not change, because an offer (of COBRA) was still made to the employee during their VH period, which they waived.



Variable Hour to Full-time

Employees that transition from part-time (ineligible for coverage) to full-time, will typically have a few different things going on with their 1095-C form.

  1. During their variable hour employment, line 14 will show 1H (no offer given) and line 16 will be 2B (employed but not full-time). Because insurance was not available to them, line 15 will be blank.
  2. If there is a waiting period before they become eligible for insurance, lines 14 and 15 will remain unchanged during this time, but line 16 will show 2D, indicating that they are in a waiting period.
  3. Once they become eligible for insurance, lines 14 and 16 will represent their full-time status and whether they accepted or waived coverage, and line 15 will show the appropriate required contribution.



In the above example, this employee worked part-time from January to March, was in a waiting period during April and May, and then was full-time and insured from June through December.



Termed Employee

If an employee termed at some point in the year, their form will differ depending on whether they were covered by a self-insured plan or a fully insured plan.


Fully-Insured Plans

Under a fully-insured plan, you are not required to report COBRA coverage taken after a termination. In this case, the employee’s 1095-C form will show their insurance status up to their termination month, and then change to a 1H/2A (No Offer of Coverage/Not-Employed) status for the remainder of the year.



In this example, the full-time employee was insured from January through April, at which time they termed.


Self-Insured Plan

If the employee was on a self-insured health plan, you are required to report COBRA coverage accepted following a termination.


COBRA Opt-Out: If the employee opts out of COBRA, the top part of their form will look identical to the Fully-Insured term above.


Because this is a self-insured plan, the individual will also be listed in the “Covered Individuals” section, with an X indicating the months they were employed (this section is not used on fully-insured plans):



COBRA Elected: If the employee elects COBRA coverage after their termination, the only difference you will see between the time they were employed and the time they were receiving COBRA coverage will be in their Required Contribution:


 

You should see a significant increase in this cost, since they will be paying the entirety of their insurance costs while covered under COBRA. Once their COBRA eligibility expires (or they opt-out), their information will be adjusted to reflect that. In the above example, the employee was no longer eligible for COBRA as of November, so line 14 was adjusted to show that no offer was given (1H), and lines 15 and 16 were left blank.


As with the opt-out individuals, for self-insured plans the months they were employed will be indicated under the “Covered Individuals” section.