An Applicable Large Employer (an employer with more than 50 full-time employees in the prior year) must provide Form 1095-C to its full-time employees. Some employers question the sections of Form 1095-C that must be completed for each employee.
An Applicable Large Employer with a fully-insured health plan completes only Parts I and II of Form 1095-C. These two sections document (a) if the employee was full-time or not, (b) if the employee received an offer of health coverage or not, and (c) what type of offer of coverage was made. Only Parts I and II are completed by an Applicable Large Employer with an insured plan because the insurance company takes care of communicating actual coverage information. The insurance company furnishes Form 1095-B to everyone covered under the plan for one or more day during the year to document that the individuals had health coverage.
An employer with a self-funded plan completes all sections of Form 1095-C: Parts I, II and III. All three parts must be completed because the employer documents offers of coverage and must provide information about of actual plan enrollment.
Some employers with large self-funded health plans may treat the health plan as its own entity that acts, for ACA purposes, as an “insurer.” These health plan entities could send Form 1095-B to covered individuals like an actual insurance company would send coverage information. If the health plan entity sends Form 1095-B to everyone covered under the plan during the year, the Applicable Large Employer member will furnish Form 1095-C to full-time employees with only Part I and Part II completed.
For assistance with Affordable Care Act data collection and reporting, contact your account manager or solutions@basusa.com.
