Reporting

Form 1095-C, line by line

Every applicable large employer files a 1095-C for each full-time employee, plus a 1094-C transmittal for the company. The codes on Part II are what the IRS uses to decide whether you owe a penalty.

Who gets a form

You must furnish a 1095-C to every employee who was full-time for at least one month of the calendar year, and to any employee (full-time or not) who was enrolled in a self-insured plan. Employees who were never full-time and never enrolled in a self-insured plan generally do not receive a form.

Terminated employees still get a form for the months they were employed — which is why accurate termination dates matter as much as active-employee data.

The three lines that matter

Line 14 — what you offered

An offer code for each month, or one code for all 12.

Code	Meaning
1A	Qualifying offer: minimum value, affordable at the federal poverty line, offered to spouse and dependents.
1E	Minimum value coverage offered to the employee, spouse and dependents (affordability shown on line 16).
1C	Minimum value coverage offered to the employee and dependents, but not the spouse.
1H	No offer of coverage for that month.

Line 15 — what it cost the employee

Required whenever line 14 shows a minimum value offer.

Report the employee's share of the lowest-cost, employee-only minimum value option — even if the employee chose a richer plan or covered family members. This is a monthly figure, and it can legitimately be $0.00.

Line 16 — why no penalty applies

Safe harbor and relief codes.

Code	Meaning
2A	Employee was not employed at all that month.
2B	Employee was not full-time that month.
2C	Employee enrolled in the coverage offered.
2D	Employee was in a limited non-assessment period (e.g. waiting period).
2F / 2G / 2H	Affordability safe harbor used: W-2, federal poverty line, or rate of pay.

Where accuracy usually breaks down

Termination dates after the last paid period. A term date later than the employee's final work period creates months of apparent coverage gaps.
Mixed pay types. The same employee showing salary in some pay periods and hourly in others distorts hour calculations and full-time determination.
Missing full-time/part-time status. Without a status, line 16 cannot be coded correctly and the employee may be treated as an unoffered full-time employee.
Stale plan data. A prior year's lowest-cost premium on line 15 is one of the most common sources of affordability errors.
Rehires and leaves of absence. Breaks in service change which non-assessment periods apply.

Deadlines to plan around

Statements to employees are due in early March following the reporting year, and electronic filing with the IRS is due by March 31. Employers filing ten or more information returns in total must file electronically.

Working backward, that means data corrections need to be finished in January — so the review work belongs in November and December.