ACA TRACK Knowledge Base

If one of your employee’s 1095-C forms contains a blank for one or more months in Line 16, this indicates that the employee should have been offered coverage during that period but was not.

If you see a blank space while reviewing your 1095 forms, review your data to ensure its accuracy.

Common reasons for a Line 16 blank include:

• The employee had the same coverage all year. Employees with the same coverage all year should have only one entry under Line 16, in the “All 12 Months” line. The individual months should be blank. This is not an error.
• Incorrect data. If your Coverage Begin or Coverage End dates are incorrect, an employee’s 1095-C forms may show a gap in coverage. To correct this, you will need to resubmit data for that employee.
• An eligible employee was not offered coverage. If an eligible employee was not offered coverage for any reason, they will receive a Line 16 blank. The reporting is accurate.
• An employee was not offered coverage within the appropriate amount of time following a waiting period. This can sometimes occur with employees who begin early in the month on a plan with a 30-day waiting period and a Coverage Effective Date of the first of the month. For example, if an employee is hired on 5/2, 30 days brings them to 6/1. Since this is the first of the month, the employee should have been offered coverage beginning in June. However, it’s an easy mistake to not offer coverage until July 1. Based on your waiting period rules, the employee would receive a blank for the month of June, because they should have been offered coverage but were not.
  • If you did not offer coverage to a full-time eligible employee in a month in which they should have been offered coverage, line 16 should be blank for that month. If you think this is incorrect, you should review your records and update your data accordingly.
  • If the employee was part-time, you should update your data to specify the employee’s Coverage Type as “Not Eligible” for any months that are blank.

If you need to make changes to a single employee’s data:

• We recommend that you submit those change as a correction. This will mean the employee will receive two 1095-C forms, but as long as the correction is made before the January 31 deadline, the IRS will only receive the final correct submission, and it will save you having to re-upload data for all of your employees.
• If you prefer the employee only receive one form, you will need to reject the entire 1095-C batch and resubmit all of your employee and dependent data as a new Actual Batch.