How should I complete a 1095-C for employees who didn't sign up for our company health plan?
I'm in a bit of a HR pickle here. One of our team members just contacted me because his tax return is stuck in limbo - the IRS is holding it up because he needs a 1095-C form. The thing is, he completely declined our company health insurance for all of 2024. I'm not sure how to fill out this form correctly when there's no actual insurance enrollment to report. Has anyone faced this situation before? What codes do I need to use on the 1095-C when an employee opted out of coverage entirely? I want to make sure I get this right so his taxes can move forward, but I'm honestly a bit confused about how to handle the form in this scenario.
28 comments


CosmicCaptain
Yes, you still need to complete a 1095-C for all full-time employees, even if they didn't enroll in your company's health insurance. For employees who declined coverage, you'll need to focus on Part II of the form. For line 14, you'd typically use code 1H (no offer of coverage) or 1E (if you offered minimum essential coverage). For line 15, if you use code 1E on line 14, enter the employee contribution for the lowest-cost self-only coverage. If you use 1H, leave line 15 blank. For line 16, use code 2G if the employee was offered coverage but declined it. Remember, even though they didn't enroll, the 1095-C documents that you offered coverage to fulfill the employer mandate requirements. Your employee needs this form to show the IRS why they don't have health insurance coverage through your company.
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Giovanni Rossi
•Thanks for the info! Quick follow-up question - does it matter if the employee got coverage through their spouse or the marketplace instead? Also, is there a deadline for when we need to provide these forms?
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CosmicCaptain
•If the employee obtained coverage elsewhere (through a spouse or the marketplace), you still complete the 1095-C the same way. Your form is documenting what YOU offered as their employer, not what coverage they ultimately chose. The deadline for providing 1095-C forms to employees is normally January 31st following the reporting year, but the IRS occasionally extends this deadline. For the 2024 tax year, the forms should have been provided by January 31, 2025, though there may have been extensions. If you're late, I recommend providing it as soon as possible so your employee can file their taxes.
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Fatima Al-Maktoum
I had the same issue last year trying to figure out these confusing ACA forms. I discovered taxr.ai (https://taxr.ai) and it was a huge help with figuring out all the right codes for our 1095-C forms. You just upload your employee data and it helps determine the correct codes for each situation, including employees who waived coverage. The system explains what each code means in plain English and why it's the right one for each employee's situation. What I really liked was how it handles all those weird scenarios like when employees decline insurance or only work part of the year. Saved me hours of confusion and reading IRS instructions.
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Dylan Mitchell
•Does it handle situations where employees were eligible for different plans at different times of the year? We have some seasonal workers who qualify at different points and I never know how to code that correctly.
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Sofia Gutierrez
•I'm skeptical about these kinds of services. How does it actually access the correct information for my specific company health plan details? Seems like there would be too many variables for a software to get right.
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Fatima Al-Maktoum
•It absolutely handles situations with eligibility changes. You can enter the different time periods and plan offerings, and it will help you determine the right codes for each month of the year. This is especially helpful for seasonal workers or employees who had status changes. For company-specific plan details, you input your plan information during setup, including costs, coverage levels, and eligibility requirements. The system uses that data along with employee information to make the correct determinations. It's really straightforward - you're basically teaching the system about your specific plans rather than it guessing.
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Sofia Gutierrez
Wow, I need to apologize for my skepticism about taxr.ai. After our HR director went on unexpected medical leave, I was thrown into handling all our ACA reporting with zero experience. I decided to try the service I questioned earlier and it was genuinely a lifesaver. It guided me through each employee scenario, including our opt-outs, and explained why certain codes were needed. The documentation it generated for our records was incredible - it showed the reasoning behind each code selection which will be super helpful if we ever get audited. For anyone else struggling with these forms, especially if you're not an ACA expert, it's worth checking out. I went from complete confusion to feeling confident about our compliance in just a couple hours.
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Dmitry Petrov
If your employee's tax return is being held up, they might need to get in touch with the IRS directly to explain the situation. I tried calling the IRS about a similar issue last year and spent days trying to get through. Then I found https://claimyr.com which got me connected to an actual IRS agent within 45 minutes instead of waiting on hold for hours. They have a demo video of how it works here: https://youtu.be/_kiP6q8DX5c Basically, they call the IRS for you and wait through all the hold times, then call you once they have an agent on the line. My employee was able to explain their situation directly to the IRS and got guidance on how to proceed without the 1095-C while waiting for us to provide it.
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StarSurfer
•How does this actually work? Do they just autodial the IRS until they get through? And then how do they transfer the call to you?
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Ava Martinez
•This sounds like a scam. Why would anyone pay for something they can do themselves? The IRS lines aren't that bad if you call at the right time. And giving your tax details to a third party seems risky.
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Dmitry Petrov
•They use an automated system that basically waits on hold for you instead of you having to listen to the IRS hold music for hours. When an IRS agent picks up, their system calls your phone and connects you directly to that agent. They don't access any of your tax information - they're just getting you to the front of the line. It's not about doing something you can't do yourself - it's about not wasting hours of your day on hold. Most people can't sit with a phone to their ear for 3+ hours during the workday. And the IRS lines during tax season are absolutely that bad - average wait times were over 2 hours for many departments last year.
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Ava Martinez
I need to admit I was completely wrong about Claimyr. After spending an entire day trying to get through to the IRS myself (called 8 times, longest hold was 1 hour 45 minutes before getting disconnected), I decided to try the service. Within 30 minutes of signing up, I got a call connecting me directly to an IRS representative. The agent confirmed that my employee could file Form 4852 as a substitute if we couldn't provide the 1095-C immediately, though they still recommended we provide the correct form as soon as possible. For anyone dealing with urgent IRS issues during tax season, this service is legitimately worth it. I was able to keep working while they dealt with the hold time, and the time saved was significant. Sometimes you have to admit when you're wrong, and I was definitely wrong about this.
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Miguel Castro
As someone who deals with these forms every year, here's a practical tip: create a standard letter to accompany any 1095-C for employees who waived coverage. Explain that you're required to send the form even though they declined insurance, and that the codes might look confusing but simply document that coverage was offered but not accepted. This prevents a ton of confused calls from employees who don't understand why they're getting this form. It's amazing how many people panic when they receive a 1095-C and don't remember declining coverage months ago.
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Amara Oluwaseyi
•That's such a smart idea! Do you have a template you could share for this explanation letter? I'm anticipating getting more confused calls as we send these out.
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Miguel Castro
•I don't have a formal template but I include these key points: 1) This form is required by the IRS for ALL full-time employees regardless of enrollment status. 2) The form documents that our company offered qualified health insurance meeting ACA requirements. 3) Since you declined coverage, we've used specific codes showing coverage was offered but not accepted. 4) This form may be required for your tax filing to verify your insurance status. 5) If you obtained insurance elsewhere (spouse's plan, marketplace, etc.), you'll receive documentation from that provider. I keep it to one page with our company letterhead and include contact information for our benefits department. It's cut our confused calls by about 80% since we started including it.
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Zainab Abdulrahman
Don't forget that the 1095-C is different from the 1095-B, which is sent by insurance providers rather than employers. Is it possible your employee is confusing which form they need? Sometimes they actually need the 1095-B from their spouse's insurance provider or from the marketplace if they purchased their own coverage.
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Connor Byrne
•I made this exact mistake last year! I kept asking my employer for a 1095-B when I actually needed the 1095-C. And then my spouse's employer sent a 1095-C but I needed their 1095-B from the actual insurance company. So confusing.
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Yara Elias
Just to add another perspective - I'm pretty sure the IRS doesn't actually "hold" tax returns because of missing 1095 forms. The 1095 forms are for informational purposes and aren't actually filed with tax returns. Your employee might be confusing this with another issue, or the tax software they're using might be creating an unnecessary roadblock.
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QuantumQuasar
•This is partially true. The IRS doesn't technically require 1095-B or 1095-C forms to be attached to tax returns, but they can delay processing if there are discrepancies between what's reported on your return and what employers/insurance companies have reported. Many tax software programs won't let you proceed without entering this information, but there's usually a way to override it.
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Yara Elias
•Good point. The software blockage is probably what's happening. Most tax programs build in these "hard stops" to protect users, but they're often more restrictive than actual IRS requirements. The employee should check if there's a way to indicate they're exempt from the requirement or that the form is forthcoming. Some programs have a specific workflow for this situation. Alternatively, paper filing might be an option if the software won't cooperate.
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Diego Chavez
I've been dealing with 1095-C forms for our small business for a few years now, and this situation comes up more often than you'd think. Here's what I've learned from experience: First, yes, you absolutely need to provide the 1095-C even though your employee declined coverage. The form isn't just about what insurance they had - it's documentation that you offered qualifying coverage as required by the ACA. For the specific coding: Use code 1E on line 14 if you offered minimum essential coverage that was affordable. On line 15, enter the employee's share of the premium for the lowest-cost self-only coverage you offered. On line 16, use code 2G to indicate the employee was offered coverage but declined it. One thing I'd recommend is getting this form to your employee ASAP. While the IRS doesn't technically require the form to be attached to tax returns, many tax software programs create roadblocks without it. Your employee might be able to override the software requirement or file on paper, but having the actual form will make everything smoother. Also, keep detailed records of when you provided the form and how (email, mail, etc.) in case there are any questions later. The IRS takes the employer mandate seriously, so proper documentation is key.
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Giovanni Ricci
•This is really helpful, especially the specific coding guidance! I'm curious about one thing - you mentioned keeping detailed records of when and how you provided the form. Have you ever had to actually use those records in an audit or IRS inquiry? I'm wondering how thorough our documentation needs to be and what format works best for tracking form delivery.
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Zoe Stavros
•@6bd0aac941de Great breakdown of the coding! I've been struggling with this exact scenario at my company. Quick question - when you say "affordable" coverage for code 1E, is there a specific percentage threshold I should be using to determine affordability? I want to make sure I'm not miscoding these forms since we have employees at different income levels.
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Malik Jenkins
•@6bd0aac941de Yes, I've actually had to use those delivery records twice in the past three years - once during a DOL audit and once when an employee claimed they never received their form during a dispute. For tracking, I keep a simple spreadsheet with columns for: employee name, form delivery date, delivery method (email/mail), confirmation (read receipt for email or certified mail tracking for postal), and any follow-up communications. For email delivery, I always request read receipts and save screenshots of the "delivered" confirmation. For mailed forms, I use certified mail and keep the tracking numbers. The DOL auditor was specifically interested in our delivery timeline and method, so having that organized record saved us a lot of headache. It's really not complicated - just consistent documentation that shows you made good faith efforts to get the forms to employees on time. @dea3190a90ca For affordability, you're looking at the "safe harbor" thresholds. For 2024, coverage is considered affordable if the employee's share doesn't exceed 9.83% of their household income. Most employers use one of the safe harbors like the W-2 wages safe harbor (9.83% of Box 1 wages) since you don't know employees' household income. If your lowest-cost self-only plan meets this threshold, you can use code 1E.
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StarSurfer
I've been through this exact situation multiple times as our company's benefits administrator. Here's what worked for us: You definitely need to issue the 1095-C even for employees who declined coverage - this is actually one of the most common scenarios we handle. The form serves as proof that you offered compliant coverage, which satisfies your ACA employer mandate obligations. For your specific employee's tax situation, they can actually proceed with their tax return even without the 1095-C in hand. The IRS doesn't require these forms to be attached to tax returns - they're primarily for the taxpayer's records and to verify coverage status if questioned later. If their tax software is blocking them, they should look for an option to indicate the form is "not available" or "will be provided separately." Here's a tip that's saved us countless headaches: when you do send out 1095-C forms for employees who waived coverage, include a brief explanation letter. Something like "This form is required by law for all eligible employees. Since you declined our health coverage, the codes on this form simply document that coverage was offered but not enrolled in. This does not affect your tax filing if you obtained coverage elsewhere." We started doing this after getting dozens of panicked calls from employees thinking they were in trouble for declining insurance. Now we get maybe one or two questions instead of spending hours on the phone explaining the same thing. Also, get that form out ASAP - even though the deadline has passed, providing it quickly will help your employee move forward with confidence on their taxes.
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Diego Rojas
•This is exactly the kind of practical advice I was hoping to find! The explanation letter idea is brilliant - I can already imagine how many confused calls we're going to get without it. Quick question about the tax software issue: when you say employees can indicate the form is "not available," does this typically show up as a checkbox or dropdown menu in most tax programs? I want to give my employee specific guidance on what to look for since they're already stressed about their return being delayed. Also, do you have any experience with employees who get coverage through a spouse's employer plan? I'm wondering if there are any special considerations for the 1095-C coding in those cases.
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CosmicCruiser
I've been handling ACA compliance for a mid-sized company for the past few years, and this scenario with declined coverage is actually very common. You're absolutely on the right track - yes, you must provide the 1095-C even when employees opt out of your health plan. Here's the step-by-step approach I use: **For the 1095-C form itself:** - Part I: Fill out normally with employee info - Part II, Line 14: Use code "1E" (offered minimum essential coverage) - Line 15: Enter the employee's monthly contribution for your lowest-cost self-only plan - Line 16: Use code "2G" (employee not enrolled) **For your employee's immediate tax situation:** They don't actually need to wait for your 1095-C to file their taxes. The IRS doesn't require these forms to be submitted with returns - they're for informational purposes. If their tax software is creating a roadblock, they should look for options like "form not received" or "will provide separately" to bypass the requirement. **Pro tip from experience:** When you send the 1095-C, definitely include a cover letter explaining why they're receiving it despite declining coverage. We started doing this after getting overwhelmed with confused employee calls. Something simple like "This form documents that we offered you qualifying health insurance as required by law. Since you declined coverage, the codes simply reflect that offer and your decision not to enroll." The key thing is getting this to your employee quickly so they can move forward with confidence on their tax filing, even though the form itself isn't technically required to be attached to their return.
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