When Employers Must File Both 1095-B and 1095-C

Form 1095-B Overview

Form 1095-B is used by insurance providers, including self-insured small employers, to report information about individuals who are covered by minimum essential coverage. The form helps the IRS verify compliance with Affordable Care Act (ACA) requirements and assists taxpayers in confirming that they had qualifying health coverage.

Form 1095-C Overview

Form 1095-C is filed by Applicable Large Employers (ALEs), generally those with 50 or more full-time employees, to report offers of health insurance coverage and enrollment. It must be furnished to each full-time employee, regardless of whether the employee accepts or declines coverage.

When Both Forms Are Required

There are situations where an employer must issue both 1095-B and 1095-C:

• Self-Insured ALEs: An employer that is both an ALE and self-funds its health insurance must file Form 1095-C for each full-time employee, including Part III of the form to report covered individuals. This essentially replaces the need for a separate 1095-B.
• Dual Reporting: If an ALE provides coverage through an insurance company, the insurer files Form 1095-B for the covered individuals, while the employer must still file Form 1095-C to report offers of coverage. In this case, both forms are issued—1095-B by the insurer and 1095-C by the employer.

Deadlines

• Furnish to employees: March 2 (or the next business day if the date falls on a weekend or holiday)
• File with the IRS: February 28 (paper) or March 31 (electronic)

Why It Matters

Failing to correctly file Forms 1095-B and 1095-C can result in significant IRS penalties. Employers should determine whether they are an ALE and whether their health coverage is self-insured or fully insured to identify their reporting responsibilities.

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