KB14-042

An employer that sponsors a self-insured health plan may report enrollment information for individuals who were not employees on any day of the calendar year by entering code 1G, an offer of coverage to employee who was not a full-time employee for any month of the calendar year, on line 14 of Part II of Form 1095-C for all twelve months and completing Part III of Form 1095-C.

Note, however, that Form 1095-C requires the recipient’s Social Security number (SSN) on line 2 in all instances. Form 1095-C cannot be used for covered individuals who have not provided a SSN to the employer regardless of whether the employer has requested the information.

Such individuals might include the following:

  • a non-employee director
  • a terminated employee receiving COBRA coverage who terminated employment in a previous calendar year
  • a retired employee who terminated employment in a previous calendar year
  • a family member (including a surviving spouse or dependent) of such a retired individual if the family member is receiving coverage independent of the individual, such as by electing individual COBRA continuation coverage.

All family members of the individual, who are covered individuals due to that individual’s enrollment, (for instance, a spouse of a retiree who is enrolled in the plan because the retiree elected their self plus spousal coverage) should be included on the same Form 1095-C as the individual who enrolls in the coverage.

For the ability to use Form 1095-B as an alternative to Form 1095-C for an individual who was not an employee on any day of the calendar year, see the instructions for Forms 1094-C and 1095-C.

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Last Review: 5/27/2016 – Revision: 1.0

Applies To:
ACA Compliance Solution