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Form 1094/1095 Requirements for Employers

Background

A Form 1095 is used for tax purposes to report information about an individual’s health care coverage. There are a few different types of 1095 forms:

  • Form 1095-A, Health Insurance Marketplace Statement: This form is provided by the Health Insurance Marketplace to individuals who enrolled in health coverage through the Marketplace. It reports information about the coverage, including any advance payments of the premium tax credit.
  • Form 1095-B, Health Coverage: This form is provided by health insurance providers (e.g., insurance companies, or self-insured employers) to individuals who had minimum essential coverage that was not obtained through the Marketplace. It reports the months of coverage for the individual and their covered family members.
  • Form 1095-C, Employer-Provided Health Insurance Offer and Coverage: This form is provided by Applicable Large Employers (ALEs) to employees who were offered health coverage. It reports information about the health coverage offered to the employee, whether the employee enrolled in the coverage, and the employee’s share of the lowest-cost monthly premium for self-only coverage.

Employer Requirements – (50+ FTE)

  • An ALE is generally an employer that had an average of at least 50 full-time employees, including full-time equivalent (FTE) employees, during the preceding calendar year.
  • An Applicable Large Employer (ALE) is required to distribute Form 1095-C to employees.
  • An Applicable Large Employer (ALE) is required to file 1094-C and 1095-C with the IRS
    • đź’ˇ Patriot does not file Form 1094-C and 1095-C or distribute 1095-C to employees.
  • If you have SimplyInsured benefits through Patriot, SimplyInsured will provide you with Forms 1094-C and 1095-C in their software. Go to Payroll > Payroll Tasks > Health Benefits.
    • If you have any additional questions about how to find Forms 1094-C and 1095-C please contact SimplyInsured support@simplyinsured.com

Employer Requirements – (Under 50 FTE)

  • If an employer is not an Applicable Large Employer (ALE) but provides minimum essential coverage (MEC), the health insurance provider is responsible for distributing Form 1095-B to covered individuals.
  • Fully insured employers who have under 50 full-time employees including full-time equivalent (FTE) employees do not need to file anything with the IRS.
    • The insurance carrier or provider files Form 1095-B with the IRS and sends a copy to the covered employees.  
  • However, if the employer is self-insured, the employer acts as the insurance provider and is therefore responsible for issuing Form 1095-B.
    • An individual coverage HRA is a self-insured group health plan and is therefore an eligible employer-sponsored plan. 

1094/1095 Distribution and Filing Responsibilities

Employer type Type of plan Who files 1095 forms Which forms Who gets the forms
Small employer (fewer than 50 full-time employees) Fully insured Insurance company 1094-B and 1095-B The insurer sends the 1095-B to each covered employee
Applicable Large Employer (ALE) (50+ full-time employees) Fully insured Employer files 1094-C and 1095-C (to show offer of coverage)
Insurance company files 1094-B and 1095-B (to show actual coverage)
Both sets get filed, one by the employer, one by the insurer Employees get a 1095-C from the employer and possibly a 1095-B from the insurer
Any size employer Self-insured Employer acts as the insurer, so it files the 1094-B/1095-B or 1094-C/1095-C depending on size Employer handles everything Employees get the 1095 from the employer

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