IRS 1095-B and 1095-C Differences Explained Efficiently

ACA Forms › IRS 1095-B and 1095-C Differences Explained Efficiently

Difference Between IRS Form 1095-B and 1095-C Explained

The most challenging aspect of filing health insurance data may be determining the correct form. Forms 1095-B and 1095-C appear similar because they relate to healthcare coverage reporting. To assist employers in selecting the correct Form 1095-B/C, we provide answers to frequently asked questions.

B Series

Filed by:

Insurance companies
Employers that offer coverage on a self-funded plan with less than 50 full-time + full-time equivalent employees

Consists of:

Form 1094-B

1 per Issuer

Issuer's information includes address, city, state, zip, and FEIN.

Form 1095-B

1 per Responsible Individual

Includes responsible individual and all covered individual information.

A 1094-B and its 1095-Bs MUST be filed together

C Series

Filed by:

Employers that offer coverage to at least 50 full-time + full-time equivalent employees
Includes employers with self-funded, fully-funded, ICHRA, and union-based plans

Consists of:

Form 1094-C

1 per Applicable Large Employer (ALE)

Includes ALE members' information, monthly head counts, and other EINs that share common ownership.

Form 1095-C

1 per Eligible Employee

Includes eligible employee information, coverage info, and other covered individuals (if applicable).

A 1094-C and its 1095-Cs MUST be filed together

What Information is Required to File ACA Forms?

Depending on the type of form, most ACA forms will consist of the following:

The recipient's info like name, address, city, state, and zip.
The employer or issuer's info like company name, contact, EIN, etc.
The coverage and plan details with codes to indicate if the coverage was affordable and met ACA guidelines.
The covered individuals' info like name, SSN, date of birth, and covered months.

What is Form 1095-B?

Form 1095-B is an information return filed by health insurance providers or employers offering self-funded coverage with fewer than 50 full-time + full-time equivalent employees.

Insurance Providers

Self-Funded Small Employers

less than 50 full-time + full-time equivalent employees

For more info on Tax Year 2023 Form 1095-B, click here.

Who is required to file Form 1095-B?

Entities that provide Minimum Essential Coverage to individuals must complete an information return regarding the coverage.

Small businesses offering self-funded health insurance should use Form 1095-B to document their coverage. Health insurance providers must also file Form 1095-B for most policy types, including individual marketplace plans and employer-sponsored insurance coverage.

When Applicable Large Employers (ALEs) offer self-insured employer-sponsored coverage to non-employees, they can use Form 1095-B instead of Form 1095-C to report this information.

What Data is Necessary to File ACA Form 1095-B Electronically?

Personal Details: Name, EIN, and Address
Employer/Coverage Provider Information: Name, EIN, and Address
Details of Issuer: Name, EIN, and Address

Consult our 1095-B guide to understand how to complete your Form 1095-B.

What is the deadline to submit ACA Form 1095-B?

Here are the critical dates for filing and distributing Form 1095-B deadlines.

February 28^th, 2024

Paper File Deadline

March 1^st, 2024

Employee Copy Deadline

April 1^st, 2024

E-File Deadline

How Do You File ACA Forms Online?

Generally, ACA filing is handled by self-filing or by using an ACA Software provider:

Simple format for data import (like Excel)
Can often use your payroll files directly
No testing, TCC, or IRS account required
Can help with questions/coding

Self-Filing

Format requires custom software development
Filing system can be slow and unreliable
Requires testing, TCC, and personal info
Errors and issues reported can be cryptic

Learn more about filing ACA Forms online.

What is Form 1095-C?

Form 1095-C is an information return filed by employers with at least 50 full-time + full-time equivalent employees. These employers are known as 'Applicable Large Employers' or ALEs by the IRS. This form tells the IRS if the employer met ACA guidelines for the healthcare coverage they offer, and it requires that employees receive a recipient copy.

Applicable Large Employers

at least 50 full-time + full-time equivalent employees for all EINs added together that share a common owner

For more info on Tax Year 2023 Form 1095-C, click here

We also recommend checking out the IRS.gov ACA FAQ, which contains many common 1095-C questions in an easy-to-understand format.

Who needs to file Form 1095-C?

ALE Members with fully insured plans must submit Form 1095-C for each full-time employee, as mandated by section 6056. Additionally, if an ALE Member provides health coverage through a self-insured plan, they must report enrollment details on Form 1095-C- Part III for every participating individual.

What is Required to E-File ACA Form 1095-C?

At a minimum, you need the following information to complete a 1095-C:

Part I - Employee: Basic census data, including the employee's name, SSN, and address

Employer or Applicable Large Employer (ALE): Company name, EIN, and address
Part II - Employee Offer of Coverage: ACA Codes Box 14 - 17, premium amounts, and optional data for ICHRA plans.
- Employee Age on January 1^st
  - This should only be completed if certain ICHRA codes (1L, 1M, 1N, 1O, 1P, 1Q, 1T, or 1U) are entered on Line 14.
- Plan Start Month
  - This should be completed with the month the employer's plan year begins. This must be completed with the two-digit number corresponding to the month (00-12). If there is no plan in which the employee was offered coverage, 00 should be entered.
- Employee Required Contribution
  - This should be completed with the employee's share of the lowest-cost self-only plan offered to the employee. This line should only be completed when specific codes (1B, 1C, 1D, 1E, 1J, 1K, 1L, 1M, 1N, 1O, 1P, 1Q, 1T, or 1U) are entered in Line 14.
- ZIP Code
  - This should only be completed if certain ICHRA codes (1L, 1M, 1N, 1O, 1P, 1Q, 1T, or 1U) are entered on Line 14.
Part III - Covered Individuals: Name, TIN, Date of Birth (optional if TIN entered), and checks for the covered months

This section should only be completed if you offered employer-sponsored, self-insured health coverage, including an individual coverage HRA.

ALL individuals covered under the offered plan should be listed here, including the employee.

Please note: each line should list a different covered individual. Either (d) or (e) should be completed for each covered individual.