Form 1095-C tells the IRS that the employer has complied with the employer shared responsibility provisions of the Affordable Care Act (ACA). As such, it is to monitor potential shared responsibility penalties that may come into play if the employer did not offer affordable health coverage. Regardless of your internal waiting period policies, under the ACA, you are not subject to a shared responsibility penalty if you offer coverage, for a full time employee, no later than the first day after their first three full months of employment.
You get a non-assessment period also with part time employees (variable hour) that includes their entire initial measurement period plus the administrative period associated with the test.
Whether an employee works full time or not, they would appear as 1H / 2D during the non-assessment period. Our use of the non-assessment period (2D) is a best practice as it limits the shared responsibility penalty risk. Again, Part II of the 1095-C is not to validate that the employee did or did not have coverage. It is to inform the IRS of the employer’s compliance with the ACA employer mandates.
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