What the Forms Capture
For each full-time employee and each month, Forms 1094-C and 1095-C report whether an offer of coverage was made, what it cost the employee, and which relief applies. The measurement record must survive until filing.
The three things to know.
Month by Month
The form is built by month. Months in a stability period or a limited non-assessment period carry their own codes, so your look-back design feeds directly into the form.
What Feeds It
Hours-of-service records, the status of each employee for each month, offer dates and employee cost for self-only coverage.
Where Errors Start
Wrong status in one month ripples into the offer code and, on audit, into a potential payment.
Sources: 26 U.S.C. § 6056. General information, not legal advice.
A worked example.
A Stability-Period Month
An employee found full-time on a 12-month look-back is covered for the whole calendar year but quits in July.
What the Rule Produces
The form reports each month she was full-time and offered coverage, and the months stop at her termination. The status months you recorded in the look-back design feed directly into the codes.
Four steps to apply it.
1. Gather status months
Pull each employee’s status by month.
2. Match offers
Add offer dates and employee cost.
3. Choose codes
Apply the IRS instructions.
4. Review
Check totals before filing.
Where it goes wrong. Trusting payroll status without reconciling it to the measurement results.
The questions that come up next.
Who files Forms 1094-C and 1095-C?
Applicable large employers, generally those that averaged 50 or more full-time employees including equivalents in the prior year.
Are the codes explained in the instructions?
Yes. The IRS instructions explain every code for lines 14 and 16, and your reporting vendor will map your data to them.
Do small employers file?
Employers that are not applicable large employers do not file these forms for the mandate, though self-insured employers file related forms.
Do part-time months appear?
Yes, with the codes for months in which the employee was not full-time.
Who prepares the forms?
Often a reporting vendor, but the employer is responsible for accuracy.
Plan-specific questions belong with ERISA counsel, and we will bring them in.
Related pages on the look-back method.
Furnishing and Filing
Instead of mailing every 1095-C, an employer may post a notice that employees can request one, up by March 2 and kept through October 15, and furnish a requested form within 30 days.
Records That Hold Up
Keep the hours report for each window, the status list, the notices and the offers, with dates.
The Full Look-Back Guide
Every rule, example and source behind this page, in one place.
Talk it through with someone who runs this every year.
We help you choose the design, document it and reconcile the hours before the numbers reach your reporting.
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