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Clearing ACA Confusion: Which Employees Get IRS Form 1095-C?

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The biggest misunderstanding we run into when talking to employers about Affordable Care Act (ACA) reporting is over who should get a 1095-C.

The buzz around this new IRS form, which often is called the ACA version of a W-2, leaves most employers believing that every employee who gets a W-2 must also get a Form 1095-C.

Not so.

A 1095-C is the employer’s statement of the availability of health care coverage at the workplace. It must go to every employee who is eligible for company-sponsored health insurance – even if they waive it, and to every employee who is on a company-sponsored plan.

Integrity Data ACA Compliance Solution_Who should get a 1095-C

Identifying which employees get a Form 1095-C can often be as intricate a process as printing the form itself.


It’s only these employees who need a 1095-C. Remember that, to comply with the reporting requirement of the ACA individual mandate, employees have their own IRS paperwork. So to file their individual tax returns accurately, they need a copy of what their employer is filing with the company’s ACA returns.

For some employers, the task of figuring out which employees to give this form to can be tougher than the printing of the form itself.

To help you understand and sort through this new compliance burden, we have the ACA-fluent team that can boil down the must-knows of 1095-C production to a 3-minute, high-level video.

And we have a robust ACA tracking and reporting engine that automatically identifies which employees get a 1095-C. To learn more about Integrity Data’s ACA Compliance Solution:


Helen Karakoudas | ACA Education Director, Integrity Data

6 Responses to “Clearing ACA Confusion: Which Employees Get IRS Form 1095-C?”

  1. Lilly says:

    I am using the look-back measurement method. I have an employee who measured part-time in my standard measurement period but did work over 130 hours in one month of 2015. Do I have to provide a 1095-C to this employee?

  2. Diana,

    Yes, you are required to provide a 1095-C form to every employee who was ACA-defined full-time (showed 130 hours of service) in any one month of the tax year.

    Helen Karakoudas
    ACA Education Director
    Integrity Data

  3. Diana says:

    Our company works in the agriculture business and we have employees come and go all year long. Month to month. No month is exactly the same as the other as far as number of employees (FT or not). If I have a lot of employees who were full time for just 1 month or 2 months of the year, am I required to provide them with a form 1095-C?

  4. Teo says:

    How do I show an employee refused coverage with a fully insured plan on the 1095C form? Or do I need to use a code?

  5. Ali,

    For this, you would use the code for whichever harbor you used to determine affordability. So that code would be either 2F, 2G or 2H.

    Helen Karakoudas
    ACA Education Director, Integrity Data

  6. Ali Duncan says:

    For line 16, I do not see any code for the situation where the employee refuses coverage. How do we mark that line for that situation?

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