ACA Forms IRS Form 1095-C Instructions 2024

Image of Form 1095-C Header Section

The IRS Form 1095-C reports health insurance offers and coverage information to the IRS. It is only used by Applicable Large Employers (ALEs).

Guidelines for Completing Form 1095-C

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.

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

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

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

    Image of Form 1095-C Part I Employee Section

    Employer or Applicable Large Employer (ALE): Company name, EIN, and address

    Image of Form 1095-C Part I Employer or Applicable Large Employer (ALE) Section

  2. Part II - Employee Offer of Coverage: ACA Codes Box 14 - 17, premium amounts, and optional data for ICHRA plans.

    Image of Form 1095-C Part II Employee Offer of Coverage

    • Employee Age on January 1st
      • 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.
  3. Part III - Covered Individuals: Name, TIN, Date of Birth (optional if TIN entered), and checks for the covered months

    Image of Form 1095-C Part III Covered Individuals

    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.

What are the 1095 Codes?

On the IRS Form 1095-C, two sets of codes are used for Lines 14 and 16.

Series 1 Codes (Line 14)

These codes provide information about the health coverage offered by the employer, including whether it was a qualifying offer and whether coverage was offered to the employee's spouse and dependents.

Includes codes: (1A, 1B, 1C, 1D, 1E, 1F, 1G, 1H, 1I, 1J, 1K, 1L, 1M, 1N, 1O, 1P, 1Q, 1R, 1S, 1T, 1U)

Read more about 1095-C Codes.
Series 2 Codes (Line 16)

Provide additional details about the employee's employment status, such as whether the employee was not employed or was not full-time during certain months, whether the employee was enrolled in coverage, or whether the employer is eligible for transition relief.

Includes codes: (2A, 2B, 2C, 2D, 2E, 2F, 2G, 2H, 2I)

Read more about ACA Codes.

When Should I Submit Form 1095-C?

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

February 28th, 2024

Paper File Deadline

March 1st, 2024

Employee Copy Deadline

April 1st, 2024

E-File Deadline

Series 1 Code Definitions

Code Definition

1A

Qualifying Offer

1B

Minimum Essential Coverage (MEC) providing Minimum Value (MV) offered to Employee (EE) only
Spouses and dependents excluded from offer

1C

Spouse excluded from offer
MEC providing MV offered to EE and at least MEC offered to dependents (not spouse)

1D

Dependents excluded from offer
MEC providing MV offered to EE and at least MEC offered to spouse (not dependents)

1E

MEC providing MV offered to EE and at least MEC offered to dependents and spouse

1F

MEC not providing MV offered to EE; or EE, spouse, and/or dependents

1G

Self-insured coverage offered to a non-employee individual or a non-Full-Time Employee for any month of the year

1H

No offer of coverage

1J

Conditional Offer

1K

Conditional Offer

For broken-down examples of ACA Code Series 1 on Form 1095-C, download our PDF Code Series 1 Guidance.

ICHRA Code Definitions

Code Definition

1L

ICHRA offered to Employee (EE) only
Affordability is determined by using EE's primary residence location ZIP code

1M

ICHRA offered to EE and dependents (not spouse)
Affordability is determined by using EE's primary residence location ZIP code

1N

ICHRA offered to EE, spouse, and dependents
Affordability is determined by using EE's primary residence location ZIP code

1O

ICHRA offered to EEs only
Using the EE's primary employment site ZIP code affordability safe harbor

1P

ICHRA offered to EE and dependents (not spouse)
Using the EE's primary employment site ZIP code affordability safe harbor

1Q

ICHRA offered to EE, spouse, and dependents
Using the EE's primary employment site ZIP code affordability safe harbor.

1R

ICHRA that is NOT affordable offered to EE; EE and spouse, and/or dependents

1S

ICHRA offered to an individual who was not an FTE

1T

ICHRA offered to EE and spouse (not dependents)
Affordability is determined using EE's primary residence location ZIP code

1U

ICHRA offered to EE and spouse (not dependents)
Using EE's primary employment site ZIP code affordability safe harbor

For broken-down examples of ACA IRCHA Codes on Form 1095-C, download our PDF Code IRCHA Series Guidance.

Series 2 Code Definitions

Code Definition

2A

The employer did not employ this person for any day during the calendar month

2B

The employee was not full-time for this month

2C

The employee enrolled in the offered coverage

2D

The employee was in an LNAP for the month

2E

The employer is eligible for the multi-employer interim relief rule

2F

The coverage is affordable based on the Form W-2 safe harbor

2G

The coverage is affordable based on the FPL safe harbor

2H

The coverage is affordable based on the Rate of Pay safe harbor

For broken-down examples of ACA Code Series 2 on Form 1095-C, download our PDF Code Series 2 Guidance.

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