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Form 1095-C Coding Guide

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Erich Ruth

Employers filing Form 1095-C must correctly report employee health coverage using Line 14 (Offer of Coverage) and Line 16 (Safe Harbor/Other Relief) codes. These codes ensure compliance with the Affordable Care Act (ACA) and help the IRS determine if employer-shared responsibility penalties apply.

If you’re filing ACA forms, the right coding is critical. Our ACA 1095 software can simplify the process, automatically applying many of these codes where possible.


Line 14 – Offer of Coverage Codes (Series 1)

Line 14 shows what type of health coverage was offered to an employee, spouse, and dependents. Common codes include:

  • 1A – Qualifying Offer: Minimum essential coverage (MEC) providing minimum value (MV) offered to employee, spouse, and dependents at affordable cost.
  • 1B – MEC providing MV offered to employee only.
  • 1C – MEC providing MV offered to employee and dependents (not spouse).
  • 1D – MEC providing MV offered to employee and spouse (not dependents).
  • 1E – MEC providing MV offered to employee, spouse, and dependents.
  • 1H – No coverage offered.

Tip: For months with no coverage, use 1H. If coverage was offered, choose the code that best matches who was eligible.


Line 16 – Safe Harbor & Relief Codes (Series 2)

Line 16 explains why an employer should not be penalized, even if coverage wasn’t offered. Common codes include:

  • 2A – Employee not employed during the month.
  • 2B – Employee not full-time or coverage ended mid-month.
  • 2C – Employee enrolled in offered coverage.
  • 2D – Employee in a limited non-assessment period (waiting period, initial measurement, etc.).
  • 2E – Multiemployer interim rule relief applies.
  • 2F, 2G, 2H – Safe harbors for affordability (Form W-2, federal poverty line, or rate of pay).

Important: If the employee enrolled in coverage, always use 2C, even if another code could apply.


Quick Coding Scenarios

  • Employee enrolled in coverage: Line 14 = 1E (if full family coverage offered); Line 16 = 2C.
  • Part-time employee not offered coverage: Line 14 = 1H; Line 16 = 2B.
  • Waiting period: Line 14 = 1H; Line 16 = 2D.
  • Union employees covered under a multiemployer plan: Line 14 = appropriate offer code; Line 16 = 2E.

Why Accurate Coding Matters

The IRS uses these codes to determine if you’ve met the Employer Shared Responsibility Provisions. Mistakes can lead to ACA penalties. Using 1095 e-filing software helps ensure compliance and simplifies the process of transmitting forms.


Final Thoughts

Filing ACA forms is not just about filling boxes — it’s about accurate coding. Missteps on Lines 14 and 16 are among the most common errors that trigger IRS penalty notices.

With 1099FIRE, you get:

If you’re preparing to file, make sure your codes are correct — and let our software help you get it right the first time.

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