Beware of Traps for the Unwary in Preparing ACA Information Returns (Part 3)


This is the third and final part of a series on traps for the unwary in preparing information returns required under the Affordable Care Act (ACA). Part one of the series included the information-return deadlines. Part two generally highlighted rules applicable to both the Form 1094-C transmittal and the Form 1095-C information statement. This part focuses on specific line items and instructions that might seem counterintuitive or inconsistent with other items or instructions.

  1. For Form 1095-C, you must enter a code in line 14—even if the employee is not a full-time employee for one or more calendar months. By contrast, line 16 of Form 1095-C may be left blank if no code applies.
  2. For Form 1095-C, line 14, report an offer of health coverage for a month only if the offer would provide coverage for every day of the calendar month. By contrast, for part III of Form 1095-C (for self-insured plans only), report health coverage for a month if the individual is covered for at least one day of the calendar month.
  3. For Form 1095-C, line 14, enter a code identifying the type of health coverage actually offered—as opposed to coverage that an employer is treated as having offered. An employer may be treated as having offered coverage when no coverage was in fact offered, e.g., for purposes of transition relief available for dependent coverage or non-calendar year plans.
  4. For purposes of Form 1095-C, line 14, an offer of COBRA continuation coverage that is made to a former employee upon termination of employment is not reported as an offer of coverage.
  5. Part III of Form 1095-C must be completed only by employers who offer self-insured health coverage in which the employee enrolled. Part III must be completed for any person who was an employee—whether full-time or non-full-time—for one or more calendar months of the year and who enrolled in coverage.
  6. For purpose of Forms 1094-C and 1095-C, a dependent does not include a spouse.
  7. An employer with an insured major medical plan and a health reimbursement arrangement (HRA) is not required to report coverage if an individual is eligible for the HRA because he or she enrolled in the major medical plan. However, separate reporting for HRA coverage is required if the HRA is integrated with another employer’s plan (e.g., a spouse’s employer-sponsored plan).

Opinions and conclusions in this post are solely those of the author unless otherwise indicated. The information contained in this blog is general in nature and is not offered and cannot be considered as legal advice for any particular situation. The author has provided the links referenced above for information purposes only and by doing so, does not adopt or incorporate the contents. Any federal tax advice provided in this communication is not intended or written by the author to be used, and cannot be used by the recipient, for the purpose of avoiding penalties which may be imposed on the recipient by the IRS. Please contact the author if you would like to receive written advice in a format which complies with IRS rules and may be relied upon to avoid penalties.