Employee Form Types and Requirements (1095B/C)

This information is not tax or legal advice. Employers are encouraged discuss potential costs and penalties with a trusted advisor.

Form Types

Group TypeEmployee Form
Small Employer Group
Fully Funded
No Form
Small Employer Group
Self-Funded
1095-B Form
Applicable Large Employer
Fully Funded
1095-C Form
Part II Only
Applicable Large Employer
Self-Funded
1095-C Form
Part II & III

A Form Should be Generated For:

  • Any Full Time Employee that was active for an entire month of the tax reporting year.
  • Any Part Time Employee that enrolled in Self-Insured coverage
  • Any employee found to be Full Time using the Lookback period method and whose stability period began within the tax reporting year.
  • Any Retiree enrolled in Self-Insured coverage for any month during the tax reporting year
  • Any terminated employee enrolled in COBRA coverage for a Self-Insured plan for any month during the tax reporting year.
  • Any Full Time employee that became Part Time and enrolled in COBRA continuation coverage.

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TIP: ACA rules suggest that an employee of an Applicable Large Employer and
is enrolled in Self-Insured coverage could get a 1095-B AND a 1095-C form.
However, the reporting requirement is also met by completing Part III of the 1095-C form.