# Instructions for Forms

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URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3Aaeb7a31009e88072

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

2025

Instructions for Forms
1094-C and 1095-C
Section references are to the Internal Revenue Code
unless otherwise noted.

Future Developments

For the latest information about developments related to
Form 1094-C, Transmittal of Employer-Provided Health
Insurance Offer and Coverage Information Returns, and
Form 1095-C, Employer-Provided Health Insurance Offer
and Coverage, and the instructions, such as legislation
enacted after they were published, go to IRS.gov/
Form1094C and IRS.gov/Form1095C.

What’s New
Alternative manner of furnishing statements.
Employers no longer have to automatically send Form
1095-C to individuals. The requirement for furnishing the
statement is met if the employer responsible for providing
the statements provides clear, conspicuous, and
accessible notice on its website that an individual may
request a copy of their statement and the copy is timely
furnished. For this purpose, the statement is timely
furnished if provided to the individual no later than the
later of January 31, 2026, or 30 days after the date of the
request. For additional guidance, see IRS.gov/irb/
2025-11_IRB#NOT-2025-15.

Additional Information

For information related to the Affordable Care Act, visit
IRS.gov/ACA. For the final regulations under section 6056,
Information Reporting by Applicable Large Employers on
Health Insurance Coverage Offered Under
Employer-Sponsored Plans, see T.D. 9661, 2014-13 I.R.B.
855, at IRS.gov/irb/2014-13_IRB#TD-9661. For the final
regulations under section 6055, Information Reporting of
Minimum Essential Coverage, see T.D. 9660, 2014-13
I.R.B. 842, at IRS.gov/irb/2014-13_IRB#TD-9660 and T.D.
9970, 2023-02 I.R.B. 311, at IRS.gov/irb/2023–
02_IRB#TD-9970. For the final regulations under section
4980H, Shared Responsibility for Employers Regarding
Health Coverage, see T.D. 9655, 2014-9 I.R.B. 541, at
IRS.gov/irb/2014-09_IRB#TD-9655. For answers to
frequently asked questions regarding the employer shared
responsibility provisions and related information reporting
requirements, visit IRS.gov.
For information related to filing Forms 1094-C and
1095-C electronically, visit IRS.gov/AIR. For FAQs
specifically related to completing Forms 1094-C and
1095-C, go to IRS.gov/Affordable-Care-Act/Employers/
Questions-and-Answers-about-Information-Reporting-byEmployers-on-Form-1094-C-and-Form-1095-C.
For additional guidance and proposed regulatory
changes relating to section 6055, including the
requirement to solicit the TIN of each covered individual
Oct 30, 2025

for purposes of the reporting of health coverage
information, see Proposed Regulations section
1.6055-1(h) and Regulations section 301.6724-1.

General Instructions for Forms
1094-C and 1095-C

See Definitions, later, for key terms used in these
instructions.

Purpose of Form

Employers with 50 or more full-time employees (including
full-time equivalent employees) in the previous year use
Forms 1094-C and 1095-C to report the information
required under sections 6055 and 6056 about offers of
health coverage and enrollment in health coverage for
their employees. Form 1094-C must be used to report to
the IRS summary information for each Applicable Large
Employer (ALE Member) (defined below) and to transmit
Forms 1095-C to the IRS. Form 1095-C is used to report
information about each employee to the IRS and to the
employee. Forms 1094-C and 1095-C are used in
determining whether an ALE Member owes a payment
under the employer shared responsibility provisions under
section 4980H. Form 1095-C is also used in determining
the eligibility of employees for the premium tax credit.
ALE Members that offer employer-sponsored,
self-insured coverage also use Form 1095-C to report
information to the IRS and to employees about individuals
who have minimum essential coverage under the
employer plan.

Who Must File

An ALE Member must file one or more Forms 1094-C
(including a Form 1094-C designated as the Authoritative
Transmittal, whether or not filing multiple Forms 1094-C),
and must file a Form 1095-C for each employee who was
a full-time employee of the ALE Member for any month of
the calendar year. Generally, the ALE Member is required
to furnish a copy of the Form 1095-C (or a substitute form)
to the employee.
An ALE Member is, generally, a single person or entity
that is an Applicable Large Employer, or if applicable,
each person or entity that is a member of an Aggregated
ALE Group. An Applicable Large Employer, generally, is
an employer with 50 or more full-time employees
(including full-time equivalent employees) in the previous
year. For purposes of determining if an employer or group
of employers is an Applicable Large Employer, all ALE
Members under common control (an Aggregated ALE
Group) are aggregated together. If the Aggregated ALE
Group, taking into account the employees of all ALE
Members in the group, employed on average 50 or more

Instructions for Form 1094-C and Form 1095-C (2025) Catalog Number 63018M
Department of the Treasury Internal Revenue Service www.irs.gov

full-time employees (including full-time equivalent
employees) on business days during the preceding
calendar year, then the Aggregated ALE Group is an
Applicable Large Employer and each separate employer
within the group is an ALE Member. Each ALE Member is
required to file Forms 1094-C and 1095-C reporting offers
of coverage to its full-time employees (even if the ALE
Member has fewer than 50 full-time employees of its own).
For more information on which employers are subject to
the employer shared responsibility provisions of section
4980H, see Employer in the Definitions section of these
instructions. For more information on determining full-time
employees, see Full-Time Employee in the Definitions
section of these instructions, which includes information
on the treatment of new hires and employees in Limited
Non-Assessment Periods.
Tip: For purposes of reporting on Forms 1094-C and
1095-C, an employee in a Limited Non-Assessment
Period is not considered a full-time employee during that
period.

Reporting by Employers That
Sponsor Self-Insured Health Plans
An employer that offers health coverage through a
self-insured health plan must report information about
each individual enrolled in such coverage. For an
employer that is an ALE Member, this information must be
reported on Form 1095-C, Part III, for any employee who is
enrolled in coverage (and any spouse or dependent of
that employee). See the option to file Form 1094-B and
Form 1095-B, rather than Form 1094-C and Form 1095-C,
to report coverage of certain nonemployees, below.
ALE Members that offer health coverage through an
employer-sponsored, self-insured health plan must
complete Form 1095-C, Parts I, II, and III, for any
employee who enrolls in the health coverage, whether or
not the employee is a full-time employee for any month of
the calendar year.

An employer that offers employer-sponsored,
self-insured health coverage but is not an ALE Member
should not file Forms 1094-C and 1095-C, but should
instead file Forms 1094-B and 1095-B to report
information for employees who enrolled in the
employer-sponsored, self-insured health coverage.
Note: If an ALE Member is offering health coverage to
employees other than under a self-insured plan, such as
through an insured health plan or a multiemployer health
plan, the issuer of the insurance or the sponsor of the plan
providing the coverage is required to furnish the
information about their health coverage to any enrolled
employees, and the ALE Member should not complete
Form 1095-C, Part III, for those employees.

Reporting of Enrollment Information for
Nonemployees: Option To Use Forms 1094-B and
1095-B
ALE Members that offer employer-sponsored, self-insured
health coverage to nonemployees who enroll in the
coverage may use Forms 1094-B and 1095-B, rather than
Form 1095-C, Part III, to report coverage for those
individuals and other family members. For this purpose, a
nonemployee includes, for example, a nonemployee
director, an individual who was a retired employee during
the entire year, or a nonemployee COBRA beneficiary,
including a former employee who terminated employment
during a previous year.
For information on reporting for nonemployees enrolled
in an employer-sponsored, self-insured health plan using
Forms 1094-B and 1095-B, see the instructions for those
forms.
For ALE Members that choose to use Form 1095-C to
report coverage information for nonemployees enrolled in
an employer-sponsored, self-insured health plan, see the
specific instructions for Form 1095-C, Part III—Covered
Individuals (Lines 18–30), later. Form 1095-C may be
used only if the individual identified on line 1 has an SSN.

For full-time employees enrolled in an ALE Member’s
self-insured coverage, including an employee who was a
full-time employee for at least 1 month of the calendar
year, the ALE Member must complete Form 1095-C, Part
II, according to the generally applicable instructions, and
should not enter code 1G on line 14 for any month. For an
employee enrolled in an ALE Member’s self-insured
coverage who is not a full-time employee for any month of
the calendar year (meaning that for all 12 calendar months
the employee was not a full-time employee), for Form
1095-C, Part II, the ALE Member must enter code 1G on
line 14 in the “All 12 Months” column or in the separate
monthly boxes for all 12 calendar months, and the ALE
Member need not complete Part II, lines 15 and 16.

If you are not using the official IRS form to furnish
statements to recipients, see Pub. 5223, General Rules
and Specifications for Affordable Care Act Substitute
Forms 1095-A, 1094-B, 1095-B, 1094-C, and 1095-C,
which explains the requirements for format and content of
substitute statements to recipients. You may develop them
yourself or buy them from a private printer. Substitute
statements furnished to recipients may be in portrait
format; however, substitute returns filed with the IRS using
paper must be printed in landscape format.

Tip: An individual coverage HRA is a self-insured group
health plan and is therefore an eligible
employer-sponsored plan. An individual is ineligible for a
premium tax credit (PTC) for a month if the individual is
covered by an individual coverage HRA or eligible for an
individual coverage HRA that is affordable.

A Form 1094-C must be filed when an ALE Member files
one or more Forms 1095-C. An ALE Member may choose
to file multiple Forms 1094-C, each accompanied by
Forms 1095-C for a portion of its employees, provided that
a Form 1095-C is filed for each employee for whom the
ALE Member is required to file. If an ALE Member files

2

Substitute Statements to Recipients

Authoritative Transmittal for ALE Members
Filing Multiple Forms 1094-C

Instructions for Forms 1094-C and 1095-C (2025)

more than one Form 1094-C, one (and only one) Form
1094-C filed by the ALE Member must be identified on
line 19, Part I, as the Authoritative Transmittal, and, on the
Authoritative Transmittal, the ALE Member must report
certain aggregate data for all full-time employees and all
employees, as applicable, of the ALE Member.
Example 1. Employer A, an ALE Member, files a
single Form 1094-C, attaching Forms 1095-C for each of
its 100 full-time employees. This Form 1094-C should be
identified as the Authoritative Transmittal on line 19, and
the remainder of the form completed as indicated in the
instructions for line 19, later.
Example 2. Employer B, an ALE Member, files two
Forms 1094-C, one for each of its two operating divisions,
Division X and Division Y. (Division X and Division Y are
units of the same ALE Member, and thus both report
under the same employer identification number (EIN);
they are not members of an Aggregated ALE Group.)
Attached to one Form 1094-C are Forms 1095-C for the
200 full-time employees of Division X, and attached to the
other Form 1094-C are Forms 1095-C for the 1,000
full-time employees of Division Y. One of these Forms
1094-C should be identified as the Authoritative
Transmittal on line 19, and should include aggregate
employer-level data for all 1,200 full-time employees of
Employer B as well as the total number of employees of
Employer B, as applicable, as required in Parts II, III, and
IV of Form 1094-C. The other Form 1094-C should not be
identified as the Authoritative Transmittal on line 19, and
should report on line 18 only the number of Forms 1095-C
that are attached to that Form 1094-C, and should leave
the remaining sections of the form blank, as indicated in
the instructions for line 19, later.
Note: Each ALE Member must file its own Forms 1094-C
and 1095-C under its own separate EIN, even if the ALE
Member is part of an Aggregated ALE Group. No
Authoritative Transmittal should be filed for an Aggregated
ALE Group.
Example 3. Assume that Employer A from Example 1
is a member of the same Aggregated ALE Group as
Employer B from Example 2. Accordingly, Employer A and
Employer B are separate ALE Members filing under
separate EINs. Forms 1094-C should be filed in the same
manner indicated in Examples 1 and 2. Employer A
should include only information about employees of
Employer A in its Authoritative Transmittal, and Employer
B should include only information about employees of
Employer B in its Authoritative Transmittal. No
Authoritative Transmittal should be filed for the
Aggregated ALE Group reporting combined data for
employees of both Employer A and Employer B.
Similar rules apply for a Governmental Unit that has
delegated its reporting responsibilities for some of its
employees to another Governmental Unit—see
Designated Governmental Entity (DGE) in the Definitions
section of these instructions for more information. In the
case of a Governmental Unit that has delegated its
reporting responsibilities for some of its employees, the
Governmental Unit must ensure that among the multiple
Forms 1094-C filed by or on behalf of the Governmental
Unit transmitting Forms 1095-C for the Governmental
Instructions for Forms 1094-C and 1095-C (2025)

Unit’s employees, one of the filed Forms 1094-C is
designated as the Authoritative Transmittal and reports
aggregate employer-level data for the Governmental Unit,
as required in Parts II, III, and IV of Form 1094-C.
Example. County is an Aggregated ALE Group made
up of the ALE Members School District, the Police District,
and the County General Office. The School District
designates the state to report on behalf of the teachers
and reports for itself for its remaining full-time employees.
In this case, either the School District or the state must file
an Authoritative Transmittal reporting aggregate
employer-level data for the School District.

One Form 1095-C for Each Employee of ALE
Member

For each full-time employee of an ALE Member, there
must be only one Form 1095-C filed for employment with
that ALE Member. For example, if an ALE Member
separately reports for each of its two divisions, the ALE
Member must combine the offer and coverage information
for any employee who worked at both divisions during the
calendar year so that a single Form 1095-C is filed for the
calendar year for that employee, which reports information
for all 12 months of the calendar year from that ALE
Member.
In contrast, a full-time employee who works for more
than one ALE Member that is a member of the same
Aggregated ALE Group must receive a separate Form
1095-C from each ALE Member. For any calendar month
in which a full-time employee works for more than one
ALE Member of an Aggregated ALE Group, only one ALE
Member is treated as the employer of that employee for
reporting purposes (generally, the ALE Member for whom
the employee worked the greatest number of hours of
service), and only that ALE Member reports for that
employee for that calendar month. The other ALE Member
is not required to report for that employee for that calendar
month, unless the other ALE Member is otherwise
required to file Form 1095-C for that employee because
the individual was a full-time employee of that ALE
Member for a different month of the same calendar year.
In this case, the individual may be treated as not
employed by that ALE Member for that calendar month. If
under these rules, an ALE Member is not required to
report for an employee for any month in the calendar year,
the ALE Member is not required to report for that full-time
employee for that calendar year. For a description of the
rules related to determining which ALE Member in an
Aggregated ALE Group is treated as the employer for a
month in this situation, see the definition of Employee.
Example. Employer A and Employer B are separate
ALE Members that belong to the same Aggregated ALE
Group. Both Employer A and Employer B offer coverage
through the AB health plan, which is an insured plan. In
January and February, Employee has 130 hours of service
for Employer A and no hours of service for Employer B. In
March, Employee has 100 hours of service for Employer A
and 30 hours of service for Employer B. In April through
December, Employee has 130 hours of service for
Employer B and no hours of service for Employer A.
Employer A is the employer of Employee for filing
purposes for January, February, and March. Employer A
3

should file Form 1095-C for Employee reporting offers of
coverage using the appropriate code on line 14 for
January, February, and March; should complete lines 15
and 16 per the instructions; and should include Employee
in the count of total employees and full-time employees
reported for those months on Form 1094-C. For the
months April through December, on Form 1095-C,
Employer A should enter code 1H (no offer of coverage)
on line 14, leave line 15 blank, and enter code 2A (not an
employee) on line 16 (since Employee is treated as an
employee of Employer B and not as an employee of
Employer A in those months), and should exclude
Employee from the count of total employees and full-time
employees reported for those months on Form 1094-C.

When To File

You will meet the requirement to file Forms 1094-C and
1095-C if the forms are properly addressed and mailed on
or before the due date. If the due date falls on a weekend
or legal holiday, then the due date is the following
business day. A business day is any day that is not a
Saturday, Sunday, or legal holiday.
Generally, you must file Forms 1094-C and 1095-C by
February 28 if filing on paper (or March 31 if filing
electronically) of the year following the calendar year to
which the return relates. For calendar year 2025, Forms
1094-C and 1095-C are required to be filed by March 2,
2026, or March 31, 2026, if filing electronically.
See Furnishing Forms 1095-C to Employees for
information on when Form 1095-C must be furnished.

Extensions
You can get an automatic 30-day extension of time to file
by completing Form 8809, Application for Extension of
Time To File Information Returns. The form may be
submitted on paper, or through the FIRE System either as
a fill-in form or an electronic file. No signature or
explanation is required for the extension. However, you
must file Form 8809 on or before the due date of the
returns in order to get the 30-day extension. Under certain
hardship conditions, you may apply for an additional
30-day extension. See the Instructions for Form 8809 for
more information.
How to apply. File Form 8809 as soon as you know that
a 30-day extension of time to file is needed. See the
instructions for Form 8809. Mail or fax Form 8809 using
the address and phone number listed in the instructions.
You can also submit the extension request online through
the FIRE System. You are encouraged to submit requests
using the online fill-in form. See Pub. 1220 for more
information on filing online or electronically.

Where To File

Send all information returns filed on paper to the following:

4

If your principal business,
office or agency, or legal
residence, in the case of an
individual, is located in:
▼
Alabama, Arizona, Arkansas,
Connecticut, Delaware, Florida,
Georgia, Kentucky, Louisiana,
Maine, Massachusetts,
Mississippi, New Hampshire,
New Jersey, New Mexico, New
York, North Carolina, Ohio,
Pennsylvania, Rhode Island,
Texas, Vermont, Virginia,
West Virginia

If your principal business,
office or agency, or legal
residence, in the case of an
individual, is located in:
▼
Alaska, California, Colorado,
District of Columbia, Hawaii,
Idaho, Illinois, Indiana, Iowa,
Kansas, Maryland, Michigan,
Minnesota, Missouri, Montana,
Nebraska, Nevada, North
Dakota, Oklahoma, Oregon,
South Carolina, South Dakota,
Tennessee, Utah, Washington,
Wisconsin, Wyoming

Use the following address:
▼

Department of the Treasury
Internal Revenue Service
Center
Austin, TX 73301

Use the following address:
▼

Department of the Treasury
Internal Revenue Service
Center
P.O. Box 219256
Kansas City, MO 64121-9256

If your legal residence or principal place of business or
principal office or agency is outside the United States, file
with the Department of the Treasury, Internal Revenue
Service Center, Austin, TX 73301.
Shipping and mailing. If you are filing on paper, send
the forms to the IRS in a flat mailing (not folded), and do
not paperclip or staple the forms together. If you are
sending many forms, you may send them in conveniently
sized packages. On each package, write your name,
number the packages consecutively, and place Form
1094-C in package number one. Postal regulations require
forms and packages to be sent by First-Class Mail.
Returns filed with the IRS must be printed in landscape
format.
Keeping copies. Generally, keep copies of information
returns you filed with the IRS or have the ability to
reconstruct the data for at least 3 years, from the due date
of the returns.

Electronic Filing
If you are required to file 10 or more
information returns during the year, you
must file the forms electronically. The
10-or-more requirement applies in the aggregate to
certain information returns. Accordingly, a filer may be
required to file fewer than 10 Forms 1094-C and 1095-C,
but still have an electronic filing obligation based on other
Instructions for Forms 1094-C and 1095-C (2025)

kinds of information returns filed. The electronic filing
requirement does not apply if you request and receive a
hardship waiver. The IRS encourages you to file
electronically even though you are filing fewer than 10
returns.
Waiver. To receive a waiver from the required filing of
information returns electronically, submit Form 8508. You
are encouraged to file Form 8508 at least 45 days before
the due date of the returns, but no later than the due date
of the return. The IRS does not process waiver requests
until January 1 of the calendar year the returns are due.
You cannot apply for a waiver for more than 1 tax year at a
time. If you need a waiver for more than 1 tax year, you
must reapply at the appropriate time each year. If a waiver
for original returns is approved, any corrections for the
same types of returns will be covered under the waiver.
However, if you submit original returns electronically but
you want to submit your corrections on paper, a waiver
must be approved for the corrections if you must file 10 or
more corrections. If you receive an approved waiver, do
not send a copy of it to the service center where you file
your paper returns. Keep the waiver for your records only.
If you are required to file electronically but fail to do so,
and you do not have an approved waiver, you may be
subject to a penalty of $340 per return for failure to file
electronically unless you establish reasonable cause.
However, you can file up to 10 returns on paper; those
returns will not be subject to a penalty for failure to file
electronically.
Pub. 5165, Guide for Electronically Filing Affordable
Care Act (ACA) Information Returns for Software
Developers and Transmitters, specifies the
communication procedures, transmission formats,
business rules, and validation procedures, and explains
when a return will be accepted, accepted with errors, or
rejected, for returns filed electronically for calendar year
2025 through the ACA Information Return (AIR) system.
To develop software for use with the AIR system, software
developers, transmitters, and issuers, including ALE
Members filing their own Forms 1094-C and 1095-C,
should use the guidelines provided in Pub. 5165 along
with the Extensible Markup Language (XML) Schemas
published on IRS.gov.
Reminder. The formatting directions in these
instructions (for example, the directions to enter the
nine-digit EIN, including the dash on line 2 of Form
1094-C) are for the preparation of paper returns. When
filing forms electronically, the formatting set forth in the
XML Schemas and Business Rules published on IRS.gov
must be followed rather than the formatting directions in
these instructions. For more information regarding
electronic filing, see Pubs. 5164 and 5165.

Substitute Returns Filed With the IRS

If you are filing your returns on paper, see Pub. 5223 for
specifications for private printing of substitute information
returns. You may not request special consideration. Only
forms that conform to the official form and the
specifications in Pub. 5223 are acceptable for filing with
the IRS. Substitute returns filed with the IRS must be
printed in landscape format.
Instructions for Forms 1094-C and 1095-C (2025)

VOID Box

Do not use this box on Form 1095-C.

Corrected Forms 1094-C and 1095-C

Tip: For information about filing corrections electronically,
see section 7.1 of Pub. 5165.

Corrected Returns
A corrected return should be filed as soon as possible
after an error is discovered. File the corrected returns as
follows.
Form 1094-C. If correcting information on the
Authoritative Transmittal (identified on Part I, line 19, as
the Authoritative Transmittal, one (and only one) of which
must be filed for each ALE Member reporting aggregate
employer-level data for all full-time employees and
employees of the ALE Member), file a standalone, fully
completed Form 1094-C, including the correct information,
and enter an “X” in the “CORRECTED” checkbox. Do not
file a return correcting information on a Form 1094-C that
is not the Authoritative Transmittal.
Caution: Do not file any other documents (for example,
Form 1095-C) with the corrected Authoritative Transmittal.
Form 1095-C. If correcting information on a Form
1095-C that was previously filed with the IRS, file a fully
completed Form 1095-C, including the correct information
and enter an “X” in the “CORRECTED” checkbox. File a
Form 1094-C (do not mark the “CORRECTED” checkbox
on Form 1094-C) with corrected Form(s) 1095-C. Furnish
the employee a copy of the corrected Form 1095-C,
unless the ALE Member was, and continues to be, eligible
for and used the alternative method of furnishing under
the Qualifying Offer Method for that employee for that
year’s furnishing. For more information, see Alternative
method of furnishing Form 1095-C to employees under
the Qualifying Offer Method.
Forms 1095-C filed with incorrect dollar amounts on
line 15, Employee Required Contribution, may fall under a
safe harbor for certain de minimis errors. The safe harbor
generally applies if no single amount in error differs from
the correct amount by more than $100. If the safe harbor
applies, you will not have to correct Form 1095-C to avoid
penalties. However, if the recipient elects for the safe
harbor not to apply, you may have to issue a corrected
Form 1095-C to avoid penalties. For more information, see
Notice 2017-9, 2017-4 I.R.B. 542, at IRS.gov/irb/2017-04
IRB/ar11.html.
Note: Enter an “X” in the “CORRECTED” checkbox only
when correcting a Form 1095-C previously filed with the
IRS. If you are correcting a Form 1095-C that was
previously furnished to a recipient, but not filed with the
IRS, write, type, or print “CORRECTED” on the new Form
1095-C furnished to the recipient.
Correcting information affecting statement furnished
to employee using an Alternative Furnishing Method
under the Qualifying Offer Method. If an ALE Member
eligible to use the Qualifying Offer Method had furnished
the employee an alternative statement, the ALE Member
must furnish the employee a corrected statement if it filed
5

a corrected Form 1095-C correcting the ALE Member’s
name, EIN, address, or contact name and telephone
number. If the ALE Member is no longer eligible to use an
alternative furnishing method for the employee for whom it
filed a corrected Form 1095-C, it must furnish a Form
1095-C to the employee and advise the employee that
Form 1095-C replaces the statement it had previously
furnished.
Caution: If you fail to file correct information returns or fail
to furnish a correct recipient statement, you may be
subject to a penalty. However, you are not required to file
corrected returns for missing or incorrect TINs if you meet
the reasonable cause criteria. For additional information,
see Pub. 1586, Reasonable Cause Regulations &
Requirements for Missing and Incorrect Name/TINs on
Information Returns.
Tip: See the charts for examples of errors and
step-by-step instructions for filing corrected returns.

Original Form 1095-C Submitted to IRS and Furnished to
Employee
IF any of the following are
incorrect ...

THEN ...

Name, SSN, ALE Member EIN

1. Prepare a new Form 1095-C.

Offer of Coverage (line 14)

2. Enter an “X” in the
“CORRECTED” checkbox at the
top of the form.

Employee Required Contribution 3. Submit corrected Forms 1095-C
with a non-authoritative Form
1094-C transmittal to the IRS.
Section 4980H Safe Harbor and
Other Relief Codes (line 16)
4. Furnish a corrected Form 1095-C
to the employee.
Covered Individuals Information

Original Authoritative Transmittal Form 1094-C
IF any of the following are
incorrect ...

THEN ...

ALE Member or Designated
Government Entity (Name
and/or EIN)

1. Prepare a new Authoritative
Transmittal, Form 1094-C.

Total number of Forms 1095-C
filed by and/or on behalf of ALE
Member

Aggregated ALE Group
Membership
Certifications of Eligibility
Minimum Essential Coverage
Offer Indicator
Section 4980H Full-Time
Employee Count for ALE
Member
Aggregated Group Indicator
Other ALE Members of
Aggregated ALE Group (Name
and/or EIN)

2. Enter an “X” in the
“CORRECTED” checkbox at the
top of the form.

3. Submit the standalone corrected
Form 1094-C with the correct
information present.

Original Alternative Furnishing Method Under the Qualifying
Offer Method Statement Furnished to Employee
IF any of the following are
incorrect ...

THEN ...

Name, SSN, ALE Member EIN

• Submission to the IRS:
1. Prepare a new Form 1095-C.
2. Enter an “X” in the
“CORRECTED” checkbox at the
top of the form.
3. Submit corrected Form
1095-Cs with a non-authoritative
Form 1094-C transmittal to the
IRS.

Offer of Coverage

• Furnish to employee:
If, after the correction, the ALE
Member is still eligible to use the
alternative furnishing method under
the Qualifying Offer Method, furnish
the employee either a Form 1095-C
or corrected statement.
If the ALE Member is no longer
eligible to use the alternative
furnishing method with respect to
the employee, furnish a Form
1095-C to the employee.

Furnishing Forms 1095-C to Employees

You will meet the requirement to furnish Form 1095-C to
an employee if the form is properly addressed and mailed
on or before the due date. If the due date falls on a
weekend or legal holiday, then the due date is the
following business day. A business day is any day that is
not a Saturday, Sunday, or legal holiday.
An ALE Member must furnish a Form 1095-C to each of
its full-time employees by March 2, 2026, for the 2025
calendar year. See Extensions of time to furnish
statements to recipients, below.

6

Instructions for Forms 1094-C and 1095-C (2025)

For more information on alternative furnishing methods
for employers, see Qualifying Offer Method, later.
Filers of Form 1095-C may truncate the social security
number (SSN) of an individual (the employee or any family
member of the employee receiving coverage) on Form
1095-C statements furnished to employees by showing
only the last four digits of the SSN and replacing the first
five digits with asterisks (*) or Xs. Truncation is not allowed
on forms filed with the IRS. In addition, an ALE Member’s
EIN may not be truncated on the statements furnished to
employees or the forms filed with the IRS.
Except as provided below, statements must be
furnished on paper by mail (or hand delivered), unless the
recipient affirmatively consents to receive the statement in
an electronic format. If mailed, the statement must be sent
to the employee’s last known permanent address, or if no
permanent address is known, to the employee’s
temporary address. For more information on furnishing
statements to non-full-time employees and nonemployees
who are enrolled in employer-sponsored self-insured
health coverage, see Alternative manner of furnishing
statements, later.
Consent to furnish statement electronically. An ALE
Member is required to obtain affirmative consent to furnish
a statement electronically. This requirement ensures that
statements are furnished electronically only to individuals
who are able to access them. The consent must relate
specifically to receiving the Form 1095-C electronically. An
individual may consent on paper or electronically, such as
by email. If consent is on paper, the individual must
confirm the consent electronically. A statement may be
furnished electronically by email or by informing the
individual how to access the statement on the ALE
Member’s website. Statements reporting coverage and
offers of coverage under an expatriate health plan,
however, may be furnished electronically unless the
recipient explicitly refuses to consent to receive the
statement in an electronic format. Specific information on
consents to furnish statements electronically can be found
in Regulations section 301.6056-2.
Extensions of time to furnish statements to recipients. The due date for furnishing Form 1095-C is
automatically extended from January 31, 2026, to March
2, 2026. Thus, no additional extensions will be granted.
Information reporting penalties. All employers subject
to the employer shared responsibility provisions and other
employers that sponsor self-insured group health plans
that fail to comply with the applicable information reporting
requirements may be subject to the general reporting
penalty provisions for failure to file correct information
returns and failure to furnish correct payee statements. For
returns required to be made and statements required to
be furnished for 2025 tax year returns, the following apply.
• The penalty for failure to file a correct information return
is $340 for each return for which the failure occurs, with
the total penalty for a calendar year not to exceed
$4,098,500.
• The penalty for failure to provide a correct payee
statement is $340 for each statement for which the failure
occurs, with the total penalty for a calendar year not to
exceed $4,098,500.
Instructions for Forms 1094-C and 1095-C (2025)

• Special rules apply that increase the per-statement and
total penalties if there is intentional disregard of the
requirement to file the returns and furnish the required
statements.
Penalties may be waived if the failure was due to
reasonable cause and not willful neglect. See section
6724 and Regulations section 301.6724-1 and
Regulations section 1.6055-1(h) (which relate to Form
1095-C, Part III). For additional information, see Pub.
1586.
Alternative manner of furnishing statements. If you
are an ALE Member that offers employer-sponsored,
self-insured health coverage and meets the requirements
of Regulations section 1.6055-1(g), you may use the
alternative manner of furnishing statements to
non-full-time employees and nonemployees who are
enrolled in the self-insured health coverage. To use the
alternative manner of furnishing statements, the following
conditions must be met.
• The employer must provide clear and conspicuous
notice, in a location on its website that is reasonably
accessible to all individuals, stating that individuals may
receive a copy of their statement upon request. The notice
must include an email address, a physical address to
which a request for a statement may be sent, and a
telephone number that individuals may use to contact the
employer with any questions. A notice posted on an
employer’s website must be written in plain, non-technical
terms and with letters of a font size large enough,
including any visual clues or graphical figures, to call to a
viewer’s attention that the information pertains to tax
statements reporting that individuals had health coverage.
For example, an employer’s website provides a clear and
conspicuous notice if it (1) includes a statement on the
main page, or a link on the main page, reading “Tax
Information,” to a secondary page that includes a
statement, in capital letters, “IMPORTANT HEALTH
COVERAGE TAX DOCUMENTS”; (2) explains how
non-full-time employees and nonemployees who are
enrolled in the plan may request a copy of Form 1095-C;
and (3) includes the employer’s email address, mailing
address, and telephone number.
• The employer must post the notice on its website by
March 2, 2026, and retain the notice in the same location
on its website through October 15, 2026.
• The employer must furnish the statement to a
requesting individual within 30 days of the date the
request is received. To satisfy this requirement, the
employer may furnish the statement electronically if the
recipient affirmatively consents.
Effective January 31, 2024, employers no longer have
to automatically send Form 1095-C to individuals.
Employers can now post a notice on its website informing
individuals that they may request a copy of the statement.
The requirement to provide the statement is met as long
as the notice satisfies the requirements set forth above
and is:
• Clear, conspicuous, and reasonably accessible to all
responsible individuals;
• Timely posted, which for tax year 2025 is by March 2,
2026, and retained until October 15 of the filing year; and
7

• Furnished to the individual no later than the later of
January 31, 2026, or 30 days after the date of the request.
For additional guidance, see IRS.gov irb/
2025-11_IRB#NOT-2025-15.

Specific Instructions for Form 1094-C
Part I—Applicable Large Employer Member
(ALE Member)
Line 1. Enter employer’s name. The employer is the ALE
Member.
Line 2. Enter the ALE Member’s EIN. Do not enter an
SSN. Enter the nine-digit EIN, including the dash.
Caution: If you are filing Form 1094-C, a valid EIN is
required at the time the form is filed. If a valid EIN is not
provided, Form 1094-C will not be processed. If you do
not have an EIN, you may apply for one online. Go to
IRS.gov/EIN. You may also apply by faxing or mailing
Form SS-4, Application for Employer Identification
Number, to the IRS. See the Instructions for Form SS-4
and Pub. 1635, Understanding Your EIN.
Lines 3–6. Enter the ALE Member’s complete address
(including room or suite no., if applicable). This address
should match the ALE Member’s address used on Form
1095-C.
Lines 7 and 8. Enter the name and telephone number of
the person to contact who is responsible for answering
any questions from the IRS regarding the filing of, or
information reported on, Form 1094-C or 1095-C. This
may be different than the contact information on line 10 of
Form 1095-C.
Note: If you are a Designated Governmental Entity (DGE)
filing on behalf of an ALE Member, complete lines 9–16. If
you are not a DGE filing on behalf of an ALE Member, do
not complete lines 9–16. Instead, skip to line 18. See
Designated Governmental Entity (DGE) in the Definitions
section of these instructions.
Line 9. If a DGE is filing on behalf of the ALE Member,
enter the name of the DGE.
Line 10. Enter the DGE’s EIN (including the dash). Do
not enter an SSN.
Caution: If you are a DGE that is filing Form 1094-C, a
valid EIN is required at the time the return is filed. If a valid
EIN is not provided, the return will not be processed. If the
DGE does not have an EIN when filing Form 1094-C, it
can get an EIN by applying online at IRS.gov/EIN or by
faxing or mailing a completed Form SS-4. See the
Instructions for Form SS-4 and Pub. 1635.
Lines 11–14. Enter the DGE’s complete address
(including room or suite no.).
Lines 15 and 16. Enter the name and telephone number
of the person to contact who is responsible for answering
any questions from the IRS regarding the filing of, or
information reported on, Form 1094-C.
Line 17. Reserved for future use.

8

Line 18. Enter the total number of Forms 1095-C
submitted with this Form 1094-C transmittal.
Line 19. If this Form 1094-C transmittal is the
Authoritative Transmittal that reports aggregate
employer-level data for the ALE Member, check the box
on line 19 and complete Parts II, III, and IV, to the extent
applicable. Otherwise, complete the signature portion of
Form 1094-C and leave the remainder of Parts II, III, and
IV blank.
There must be only one Authoritative Transmittal filed
for each ALE Member. If this is the only Form 1094-C
being filed for the ALE Member, this Form 1094-C must
report aggregate employer-level data for the ALE Member
and be identified on line 19 as the Authoritative
Transmittal. If multiple Forms 1094-C are being filed for an
ALE Member so that Forms 1095-C for all full-time
employees of the ALE Member are not attached to a
single Form 1094-C transmittal (because Forms 1095-C
for some full-time employees of the ALE Member are
being transmitted separately), one (and only one) of the
Forms 1094-C must report aggregate employer-level data
for the ALE Member and be identified on line 19 as the
Authoritative Transmittal. For more information, see
Authoritative Transmittal for ALE Members Filing Multiple
Forms 1094-C, earlier.

Part II—ALE Member Information
Reminder. Lines 20–22 should be completed only on the
Authoritative Transmittal for the ALE Member. For more
information, see Authoritative Transmittal for ALE
Members Filing Multiple Forms 1094-C, earlier.
Line 20. Enter the total number of Forms 1095-C that will
be filed by, and/or on behalf of, the ALE Member. This
includes all Forms 1095-C that are filed with this
transmittal, including those filed for individuals who
enrolled in the employer-sponsored, self-insured plan, if
any, and for any Forms 1095-C filed with a separate
transmittal filed by, or on behalf of, the ALE Member.
Line 21. If during any month of the calendar year the ALE
Member was a member of an Aggregated ALE Group,
check “Yes.” If you check “Yes,” also complete the
“Aggregated Group Indicator” in Part III, column (d), and
then complete Part IV to list the other members of the
Aggregated ALE Group. If, for all 12 months of the
calendar year, the employer was not a member of an
Aggregated ALE Group, check “No,” and do not complete
Part III, column (d), or Part IV.
Line 22. If the ALE Member meets the eligibility
requirements and is using one of the Offer Methods, it
must check the applicable box. See the descriptions of
Qualifying Offer Method and 98% Offer Method, later.
A. Qualifying Offer Method. Check this box if the ALE
Member is eligible to use, and is using, the Qualifying
Offer Method to report the information on Form 1095-C for
one or more full-time employees. Under the Qualifying
Offer Method, there is an alternative method of completing
Form 1095-C and an alternative method for furnishing
Form 1095-C to certain employees. If the ALE Member is
using either of these alternative rules, check this box. To
be eligible to use the Qualifying Offer Method, the ALE
Member must certify that it made a Qualifying Offer to one
Instructions for Forms 1094-C and 1095-C (2025)

or more of its full-time employees for all months during the
year in which the employee was a full-time employee for
whom an employer shared responsibility payment could
apply. Additional requirements described below must be
met to be eligible to use the alternative method for
furnishing Form 1095-C to employees under the
Qualifying Offer Method.
Alternative method of completing Form 1095-C
under the Qualifying Offer Method. If the ALE Member
reports using this method, it must not complete Form
1095-C, Part II, line 15, for any month for which a
Qualifying Offer is made. Instead, it must enter the
Qualifying Offer code 1A on Form 1095-C, line 14, for any
month for which the employee received a Qualifying Offer
(or in the “All 12 Months” box if the employee received a
Qualifying Offer for all 12 months), and must leave line 15
blank for any month for which code 1A is entered on
line 14. The ALE Member may, but is not required to, enter
an applicable code on line 16 for any month for which
code 1A is entered on line 14; a Qualifying Offer is, by
definition, treated as an offer that falls within an
affordability safe harbor even if no code is entered on
line 16.
An ALE Member is not required to use the Qualifying
Offer Method even if it is eligible, and instead may enter
on line 14 the applicable offer code and then enter on
line 15 the Employee Required Contribution.
Tip: If the ALE Member is eligible to use the Qualifying
Offer Method, it may report on Form 1095-C by entering
the Qualifying Offer code 1A on Form 1095-C, line 14, for
any month for which it made a Qualifying Offer to an
employee, even if the employee did not receive a
Qualifying Offer for all 12 calendar months. However, if an
employee receives a Qualifying Offer for less than all 12
months, the ALE Member must furnish a copy of Form
1095-C to the employee (rather than using the alternative
method of furnishing Form 1095-C described later).
Example. Employee’s employment with Employer
begins on January 1. Employee is in a health coverage
waiting period (and an employer shared responsibility
payment could not apply with respect to Employee,
because Employee is in a Limited Non-Assessment
Period) until April 1 and is a full-time employee for the
remainder of the calendar year. Employer makes a
Qualifying Offer to Employee for coverage beginning on
April 1 and for the remainder of the calendar year.
Employer is eligible to use the Qualifying Offer method
because it has made a Qualifying Offer to at least one
full-time employee for all months in which both (1) the
employee was a full-time employee, and (2) an employer
shared responsibility payment could apply with respect to
the employee. Employer may use the alternative method
of completing Form 1095-C under the Qualifying Offer
Method for this Employee. However, Employer may not
use the alternative method of furnishing Form 1095-C to
Employee under the Qualifying Offer Method because
Employee did not receive a Qualifying Offer for all 12
months of the calendar year.
Alternative method of furnishing Form 1095-C to
employees under the Qualifying Offer Method. An
ALE Member that is eligible to use the Qualifying Offer
Method may use the alternative method of furnishing Form
Instructions for Forms 1094-C and 1095-C (2025)

1095-C only for a full-time employee who (1) received a
Qualifying Offer for all 12 months of the calendar year, and
(2) did not enroll in employer-sponsored, self-insured
coverage. For such an employee, an ALE Member meets
its obligation to furnish a Form 1095-C to the employee if it
furnishes the employee a statement containing the
following information.
• Employer/ALE Member name, address, and EIN.
• Contact name and telephone number at which the
employee may receive information about the offer of
coverage and the information on the Form 1095-C filed
with the IRS for that employee.
• Notification that, for all 12 months of the calendar year,
the employee and their spouse and dependents, if any,
received a Qualifying Offer and therefore the employee is
not eligible for a premium tax credit.
• Information directing the employee to see Pub. 974,
Premium Tax Credit (PTC), for more information on
eligibility for the premium tax credit.
An ALE Member is not required to use the alternative
method of furnishing for an employee even if the
alternative method would be allowed. Instead, the ALE
Member may furnish a copy of Form 1095-C as filed with
the IRS (with or without the statement described earlier).
As stated earlier, an ALE Member may not use the
alternative furnishing method for a full-time employee who
enrolled in self-insured coverage. Rather, the ALE
Member must furnish Form 1095-C, including the
information reporting enrollment in the coverage on Form
1095-C, Part III.
B. Reserved for future use.
C. Reserved for future use.
D. 98% Offer Method. Check this box if the employer
is eligible for, and is using, the 98% Offer Method. To be
eligible to use the 98% Offer Method, an employer must
certify that, taking into account all months during which
the individuals were employees of the ALE Member and
were not in a Limited Non-Assessment Period, the ALE
Member offered affordable health coverage providing
minimum value to at least 98% of its employees for whom
it is filing a Form 1095-C employee statement, and offered
minimum essential coverage to those employees’
dependents. The ALE Member is not required to identify
which of the employees for whom it is filing were full-time
employees, but the ALE Member is still required, under
the general reporting rules, to file Forms 1095-C on behalf
of all its full-time employees who were full-time employees
for 1 or more months of the calendar year. To ensure
compliance with the general reporting rules, an ALE
Member should confirm for any employee for whom it fails
to file a Form 1095-C that the employee was not a full-time
employee for any month of the calendar year. For this
purpose, the health coverage is affordable if the ALE
Member meets one of the section 4980H affordability safe
harbors.
Example. Employer has 325 employees. Of those 325
employees, Employer identifies 25 employees as not
possibly being full-time employees because they are
scheduled to work 10 hours per week and are not eligible
for additional hours. Of the remaining 300 employees, 295
are offered affordable minimum value coverage for all
periods during which they are employed other than any
9

applicable waiting period (which qualifies as a Limited
Non-Assessment Period). Employer files a Form 1095-C
for each of the 300 employees (excluding the 25
employees that it identified as not possibly being full-time
employees). Employer may use the 98% Offer Method
because it makes an affordable offer of coverage that
provides minimum value to at least 98% of the employees
for whom Employer files a Form 1095-C. Using this
method, Employer does not identify whether each of the
300 employees is a full-time employee. However,
Employer must still file a Form 1095-C for all of its full-time
employees. Employer chooses to file a Form 1095-C on
behalf of all 300 employees, including the five employees
to whom it did not offer coverage, because if one or more
of those employees was, in fact, a full-time employee for 1
or more months of the calendar year, Employer would be
required to have filed a Form 1095-C on behalf of those
employees.
Note: If an ALE Member uses the 98% Offer Method, it is
not required to complete the “Section 4980H Full-Time
Employee Count for ALE Member” in Part III, column (b).

Part III—ALE Member Information—Monthly
(Lines 23–35)
Column (a)—Minimum Essential Coverage Offer Indicator.
• If the ALE Member offered minimum essential
coverage, including an individual coverage HRA, to at
least 95% of its full-time employees and their dependents
for the entire calendar year, enter “X” in the “Yes”
checkbox on line 23 for “All 12 Months” or for each of the
12 calendar months.
• If the ALE Member offered minimum essential
coverage, including an individual coverage HRA, to at
least 95% of its full-time employees and their dependents
only for certain calendar months, enter “X” in the “Yes”
checkbox for each applicable month.
• For the months, if any, for which the ALE Member did
not offer minimum essential coverage, including an
individual coverage HRA, to at least 95% of its full-time
employees and their dependents, enter “X” in the “No”
checkbox for each applicable month.
• If the ALE Member did not offer minimum essential
coverage, including an individual coverage HRA, to at
least 95% of its full-time employees and their dependents
for any of the 12 months, enter “X” in the “No” checkbox
for “All 12 Months” or for each of the 12 calendar months.
Note: For purposes of column (a), an employee in a
Limited Non-Assessment Period is not counted in
determining whether minimum essential coverage was
offered to at least 95% of an ALE Member’s full-time
employees and their dependents. For a description of the
differences between the definition of the term “Limited
Non-Assessment Period” used with respect to section
4980H(a) and the definition used with respect to section
4980H(b), relating to whether the ALE Member offers
minimum value coverage at the end of the Limited
Non-Assessment Period, see the Definitions section.
Tip: An employee who is treated as having been offered
health coverage, including an individual coverage HRA,
10

for purposes of section 4980H (even though not actually
offered) is treated as offered minimum essential coverage
for this purpose. For example, for the months for which the
ALE Member is eligible for multiemployer arrangement
interim guidance (if the ALE Member is contributing on
behalf of an employee whether or not the employee is
eligible for coverage under the multiemployer plan) with
respect to an employee, that employee should be treated
as having been offered minimum essential coverage for
purposes of column (a). For different rules for purposes of
reporting offers of coverage on Form 1095-C, see the
specific instructions for Form 1095-C, Part II, Line 14.
Tip: For purposes of column (a), if the ALE Member
offered minimum essential coverage to all but five of its
full-time employees and their dependents, and five is
greater than 5% of the number of full-time employees of
the ALE Member, the ALE Member may report in column
(a) as if it offered health coverage to at least 95% of its
full-time employees and their dependents (even if it
offered health coverage to less than 95% of its full-time
employees and their dependents, for example, to 75 of its
80 full-time employees and their dependents).
See Definitions, later, for more information on an offer
of health coverage.
Column (b)—Section 4980H Full-Time Employee
Count for ALE Member. Enter the number of full-time
employees for each month, but do not count any
employee in a Limited Non-Assessment Period. If the
number of full-time employees (excluding employees in a
Limited Non-Assessment Period) for a month is zero,
enter -0-. An employee should be counted as a full-time
employee for a month if the employee satisfied the
definition of “full-time employee” under the monthly
measurement method or the look-back measurement
method (as applicable) on any day of the month. See
Full-time employee and Limited Non-Assessment Period
in the Definitions section. Be sure to use the section
4980H definition and not any other definition of the term
“full-time employee” that you may use for other purposes.
Example. Employer uses the look-back measurement
method to determine the full-time status of its employees.
Employee, who is not in a Limited Non-Assessment
Period, averaged over 130 hours of service per month
during the measurement period that corresponds with the
stability period starting January 1, 2025, and ending
December 31, 2025. Employee terminates employment
with Employer on February 15, 2025. Employer must
include Employee in the number of full-time employees
reported in column (b) for January and February. See the
description of code 2B in the instructions for line 16 of
Form 1095-C, later, for rules for reporting an offer of
coverage in an employee’s final month of employment.
Note: If the ALE Member certified that it was eligible for
the 98% Offer Method by selecting box D, on line 22, it is
not required to complete column (b).
Column (c)—Total Employee Count for ALE Member.
Enter the total number of all of the ALE Member’s
employees, including full-time employees and
non-full-time employees, and employees in a Limited
Non-Assessment Period, for each calendar month. An
Instructions for Forms 1094-C and 1095-C (2025)

ALE Member must choose to use one of the following
days of the month to determine the number of employees
per month and must use that day for all months of the
year: (1) the 1st day of each month, (2) the last day of
each month, (3) the 12th day of each month, (4) the 1st
day of the 1st payroll period that starts during each month,
or (5) the last day of the 1st payroll period that starts
during each month (provided that for each month that last
day falls within the calendar month in which the payroll
period starts). If the total number of employees was the
same for every month of the entire calendar year, enter
that number in line 23, column (c), “All 12 Months,” or in
the boxes for each month of the calendar year. If the
number of employees for any month is zero, enter -0-.
Column (d)—Aggregated Group Indicator. An ALE
Member must complete this column if it checked “Yes” on
line 21, indicating that, during any month of the calendar
year, it was a member of an Aggregated ALE Group. If the
ALE Member was a member of an Aggregated ALE Group
during each month of the calendar year, enter “X” in the
“All 12 Months” box or in the boxes for each of the 12
calendar months. If the ALE Member was not a member of
an Aggregated ALE Group for all 12 months but was a
member of an Aggregated ALE Group for 1 or more
month(s), enter “X” in each month for which it was a
member of an Aggregated ALE Group. If an ALE Member
enters “X” in 1 or more months in this column, it must also
complete Part IV.

Part IV—Other ALE Members of Aggregated ALE
Group (Lines 36–65)
An ALE Member must complete this section if it checks
“Yes” on line 21. If the ALE Member was a member of an
Aggregated ALE Group (with other ALE Members) for any
month of the calendar year, enter the name(s) and EIN(s)
of up to 30 of the other Aggregated ALE Group members
(not including the reporting ALE Member). If there are
more than 30 members of the Aggregated ALE Group (not
including the reporting ALE Member), enter the 30 with
the highest monthly average number of full-time
employees (using the number reported in Part III, column
(b), if a number was required to be reported) for the year
or for the number of months during which the ALE
Member was a member of the Aggregated ALE Group. If
any member of the Aggregated ALE Group uses the 98%
Offer Method and thus is not required to identify which
employees are full-time employees, all ALE Members of
the Aggregated ALE Group should use the monthly
average number of total employees rather than the
monthly average number of full-time employees for this
purpose. Regardless of the number of members in the
Aggregated ALE Group, list only the 30 members in
descending order, listing first the member with the highest
average monthly number of full-time employees (or
highest average number of total employees, if any
member of the Aggregated ALE Group uses the 98%
Offer Method), but do not include the reporting ALE
Member. The reporting ALE Member must also complete
Part III, column (d), to indicate which months it was part of
an Aggregated ALE Group.
Caution: If you are filing Form 1094-C, a valid EIN is
required at the time it is filed. If a valid EIN is not provided,
Instructions for Forms 1094-C and 1095-C (2025)

Form 1094-C will not be processed. If you do not have an
EIN, you may apply for one online. Go to IRS.gov/EIN. You
may also apply by faxing or mailing Form SS-4 to the IRS.
See the Instructions for Form SS-4 and Pub. 1635.

Specific Instructions for Form 1095-C
Part I—Employee
Line 1. Enter the name of the employee (first name,
middle initial, last name).
Line 2. Enter the nine-digit SSN of the employee
(including the dashes).
Lines 3–6. Enter the employee’s complete address,
including apartment no., if applicable. A country code is
not required for U.S. addresses.

Part I—Applicable Large Employer Member
(Employer)
Line 7. Enter the name of the ALE Member.
Line 8. Enter the ALE Member’s EIN. Do not enter an
SSN. Enter the nine-digit EIN, including the dash. The
ALE Member’s name and EIN should match the name and
EIN of the ALE Member reported on lines 1 and 2 of Form
1094-C.
Caution: If you are filing Form 1095-C, a valid EIN is
required at the time it is filed. If a valid EIN is not provided,
Form 1095-C will not be processed. If you do not have an
EIN, you may apply for one online. Go to IRS.gov/EIN. You
may also apply by faxing or mailing Form SS-4 to the IRS.
See the Instructions for Form SS-4 and Pub. 1635.
Lines 9 and 11–13. Enter the ALE Member’s complete
address (including room or suite no., if applicable). This
address should match the address reported on lines 3–6
of the Form 1094-C.
Line 10. Enter the telephone number of the person to
contact whom the recipient may call about the information
reported on the form. This may be different than the
contact information entered on line 8 of Form 1094-C.

Part II—Employee Offer of Coverage
Age. If the employee was offered an individual coverage
HRA, enter the employee’s age on January 1, 2025. Note
that for non-calendar year plans or for employees who
become eligible during the plan year, this age may not be
the Applicable age used to determine Employee Required
Contribution.
Plan Start Month. This box is required for the 2025 Form
1095-C and the ALE Member may not leave it blank. To
complete the box, enter the two-digit number (01 through
12) indicating the calendar month during which the plan
year begins of the health plan in which the employee is
offered coverage (or would be offered coverage if the
employee were eligible to participate in the plan). If more
than 1 plan year could apply (for instance, if the ALE
Member changes the plan year during the year), enter the
earliest applicable month. If there is no health plan under
which coverage is offered to the employee, enter “00.”

11

Line 14. For each calendar month, enter the applicable
code from Code Series 1. If the same code applies for all
12 calendar months, you may enter the applicable code in
the “All 12 Months” box and not complete the individual
calendar month boxes, or you may enter the code in each
of the boxes for the 12 calendar months. If an employee
was not offered coverage for a month, enter code 1H. Do
not leave line 14 blank for any month (including months
when the individual was not an employee of the ALE
Member). An ALE Member offers health coverage for a
month only if it offers health coverage that would provide
coverage for every day of that calendar month. Thus, if
coverage terminates before the last day of the month
(because, for instance, the employee terminates
employment with the ALE Member, or otherwise loses
eligibility for coverage under the plan), the employee does
not actually have an offer of coverage for that month (and
code 1H should therefore be entered on line 14). See
line 16, code 2B, later, for how the ALE Member may
complete line 16 in the event that coverage terminates
before the last day of the month.
A code must be entered for each calendar month,
January through December, even if the employee was not
a full-time employee for 1 or more of the calendar months.
Enter the code identifying the type of health coverage
actually offered by the ALE Member (or on behalf of the
ALE Member) to the employee, if any. If the employee was
not actually offered coverage, enter code 1H (no offer of
coverage) on line 14.
For reporting offers of coverage for 2025, an ALE
Member relying on the multiemployer arrangement interim
guidance should enter code 1H on line 14 for any month
for which the ALE Member enters code 2E on line 16
(indicating that the ALE Member was required to
contribute to a multiemployer plan on behalf of the
employee for that month and therefore is eligible for
multiemployer interim rule relief). For a description of the
multiemployer arrangement interim guidance, see Offer of
health coverage in the Definitions section. For reporting
for 2025, code 1H may be entered without regard to
whether the employee was eligible to enroll, or enrolled in,
coverage under the multiemployer plan. For reporting for
2026 and future years, ALE Members relying on the
multiemployer arrangement interim guidance may be
required to report offers of coverage made through a
multiemployer plan in a different manner.

Indicator Codes for Employee Offer of Coverage
(Form 1095-C, Line 14)
Code Series 1—Offer of Coverage. The Code Series 1
indicator codes specify the type of coverage, if any,
offered to an employee, the employee’s spouse, and the
employee’s dependents. The term Dependent has the
specific meaning set forth in the Definitions section of
these instructions. In addition, for this purpose, an offer of
coverage is treated as made to an employee’s
dependents only if the offer of coverage is made to an
unlimited number of dependents regardless of the actual
number of dependents, if any, an employee has during
any particular calendar month.

12

If the type of coverage, if any, offered to an employee
was the same for all 12 months in the calendar year, enter
the Code Series 1 indicator code corresponding to the
type of coverage offered either in the “All 12 Months” box
or in each of the 12 boxes for the calendar months.
Conditional offer of spousal coverage. Codes 1J
and 1K address conditional offers of spousal coverage
(also referred to as “coverage offered conditionally”). A
conditional offer is an offer of coverage that is subject to
one or more reasonable, objective conditions (for
example, an offer to cover an employee’s spouse only if
the spouse is not eligible for coverage under Medicare or
a group health plan sponsored by another employer).
Using codes 1J and 1K, an ALE Member may report a
conditional offer to a spouse as an offer of coverage,
regardless of whether the spouse meets the reasonable,
objective condition. A conditional offer may impact a
spouse’s eligibility for the premium tax credit under
section 36B only if all conditions to the offer are satisfied
(that is, the spouse was actually offered the coverage and
eligible for it) and the Exchange makes a determination
about the affordability of the offer. To help employees (and
spouses) who have received a conditional offer determine
their eligibility for the premium tax credit, the ALE Member
should be prepared to provide, upon request, a list of any
and all conditions applicable to the spousal offer of
coverage. As is noted in the definition of Dependent in the
Definitions section, a spouse is not a dependent for
purposes of section 4980H.
An ALE Member may not report a conditional offer of
coverage to an employee’s dependents as an offer to the
dependents, unless the ALE Member knows that the
dependents met the condition to be eligible for the ALE
Member’s coverage. Further, an offer of coverage is
treated as made to an employee’s dependents only if the
offer of coverage is made to an unlimited number of
dependents regardless of the actual number of
dependents, if any, an employee has during any particular
calendar month.
COBRA continuation coverage. An offer of COBRA
continuation coverage is reported differently depending on
whether or not the offer is made due to an employee’s
termination of employment.
An offer of COBRA continuation coverage that is made
to a former employee (or to a former employee’s spouse
or dependents) due to termination of employment should
not be reported as an offer of coverage on line 14. In this
situation, code 1H (no offer of coverage) must be entered
on line 14 for any month for which the offer of COBRA
continuation coverage applies, and code 2A (Employee
not employed during the month) must be entered on
line 16 (see the instructions for line 16), without regard to
whether the employee or spouse or dependents enrolled
in the COBRA coverage. However, for the month in which
the employee terminates employment with the ALE
Member, see the instructions for line 16, code 2B.
An offer of COBRA continuation coverage that is made
to an employee who remains employed by the ALE
Member (or to that employee’s spouse and dependents)
should be reported on line 14 as an offer of coverage, but
only for any individual who receives an offer of COBRA
continuation coverage (or an offer of similar coverage that
Instructions for Forms 1094-C and 1095-C (2025)

is made at the same time as the offer of COBRA
continuation coverage is made to enrolled individuals).
Generally, an offer of COBRA continuation coverage is
required to be made only to individuals who were enrolled
in coverage and would lose eligibility for coverage due to
the COBRA qualifying event, but an ALE Member may
choose to extend a similar offer of coverage to a spouse
or dependent even if the offer is not required by COBRA.
Example. During the applicable open enrollment
period for its health plan, Employer makes an offer of
minimum essential coverage providing minimum value to
Employee and to Employee’s spouse and dependents.
Employee elects to enroll in employee-only coverage
starting January 1. On June 1, Employee experiences a
reduction in hours that results in loss of eligibility for
coverage under the plan. As of June 1, Employer
terminates Employee’s existing coverage and makes an
offer of COBRA continuation coverage to Employee, but
does not make an offer to Employee’s spouse and
dependents. Employer should enter code 1E (Minimum
essential coverage providing minimum value offered to
employee and at least minimum essential coverage
offered to dependent(s) and spouse) on line 14 for months
January–May, and should enter code 1B (Minimum
essential coverage providing minimum value offered to
employee only) on line 14 for months June–December.
Note: Notwithstanding the preceding instructions for
completing line 14 of Form 1095-C, for purposes of
section 4980H, an ALE Member is treated as having
made an offer to the employee’s dependents for an entire
plan year if the ALE Member provided the employee an
effective opportunity to enroll the employee’s dependents
at least once for the plan year, even if the employee
declined to enroll the dependents in the coverage and, as
a result, the dependents later did not receive an offer of
COBRA coverage.
Post-employment (non-COBRA) coverage. An offer
of post-employment coverage to a former employee (or to
that former employee’s spouse or dependent(s)) for
coverage that would be effective after the employee has
terminated employment (such as at retirement) should not
be reported as an offer of coverage on line 14. If the ALE
Member is otherwise required to file Form 1095-C for the
former employee (because, for example, the individual
was a full-time employee for 1 or more months in the
calendar year in which the termination of employment
occurred), the ALE Member should enter code 1H (no
offer of coverage) on line 14 for any month to which an
offer of post-employment coverage applies, and should
also enter code 2A (not an employee) on line 16 (see the
instructions for line 16).
Tip: For additional information, including examples about
reporting offers of COBRA continuation coverage and
post-employment coverage, go to IRS.gov/AffordableCare-Act/Employers/Questions-and-Answers-aboutInformation-Reporting-by-Employers-on-Form-1094-Cand-Form-1095-C.
• 1A. Qualifying Offer: Minimum essential coverage
providing minimum value offered to full-time employee
with Employee Required Contribution equal to or less than
9.5% (as adjusted) of mainland single federal poverty line
Instructions for Forms 1094-C and 1095-C (2025)

and at least minimum essential coverage offered to
spouse and dependent(s).
Tip: This code may be used to report for specific months
for which a Qualifying Offer was made, even if the
employee did not receive a Qualifying Offer for all 12
months of the calendar year. However, an ALE Member
may not use the Alternative Furnishing Method for an
employee who did not receive a Qualifying Offer for all 12
calendar months.
• 1B. Minimum essential coverage providing minimum
value offered to employee only.
• 1C. Minimum essential coverage providing minimum
value offered to employee and at least minimum essential
coverage offered to dependent(s) (not spouse).
• 1D. Minimum essential coverage providing minimum
value offered to employee and at least minimum essential
coverage offered to spouse (not dependent(s)). Do not
use code 1D if the coverage for the spouse was offered
conditionally. Instead, use code 1J.
• 1E. Minimum essential coverage providing minimum
value offered to employee and at least minimum essential
coverage offered to dependent(s) and spouse. Do not use
code 1E if the coverage for the spouse was offered
conditionally. Instead, use code 1K.
• 1F. Minimum essential coverage NOT providing
minimum value offered to employee; employee and
spouse or dependent(s); or employee, spouse, and
dependents.
• 1G. Offer of coverage for at least 1 month of the
calendar year to an individual who was not an employee
for any month of the calendar year or to an employee who
was not a full-time employee for any month of the calendar
year (which may include 1 or more months in which the
individual was not an employee) and who enrolled in
self-insured coverage for 1 or more months of the
calendar year.
Note: Code 1G applies for the entire year or not at all.
Therefore, if code 1G applies, an ALE Member must enter
code 1G on line 14 in the “All 12 Months” column or in
each separate monthly box (for all 12 months).
• 1H. No offer of coverage (employee not offered any
health coverage or employee offered coverage that is not
minimum essential coverage, which may include 1 or
more months in which the individual was not an
employee).
• 1I. Reserved for future use.
• 1J. Minimum essential coverage providing minimum
value offered to employee and at least minimum essential
coverage conditionally offered to spouse; minimum
essential coverage not offered to dependent(s). (See
Conditional offer of spousal coverage, earlier, for an
additional description of conditional offers.)
• 1K. Minimum essential coverage providing minimum
value offered to employee; at least minimum essential
coverage offered to dependents; and at least minimum
essential coverage conditionally offered to spouse. (See
Conditional offer of spousal coverage, earlier, for an
additional description of conditional offers.)
• 1L. Individual coverage HRA offered to employee only
with affordability determined by using employee’s primary
residence location ZIP code.
13

• 1M. Individual coverage HRA offered to employee and
dependent(s) (not spouse) with affordability determined
by using employee’s primary residence location ZIP code.
• 1N. Individual coverage HRA offered to employee,
spouse, and dependent(s) with affordability determined by
using employee’s primary residence location ZIP code.
• 1O. Individual coverage HRA offered to employees only
using the employee’s primary employment site ZIP code
affordability safe harbor.
• 1P. Individual coverage HRA offered to employee and
dependent(s) (not spouse) using the employee’s primary
employment site ZIP code affordability safe harbor.
• 1Q. Individual coverage HRA offered to employee,
spouse, and dependent(s) using employee’s primary
employment site ZIP code affordability safe harbor.
• 1R. Individual coverage HRA that is NOT affordable
offered to employee; employee and spouse, or
dependent(s); or employee, spouse, and dependents.
• 1S. Individual coverage HRA offered to an individual
who was not a full-time employee.
• 1T. Individual coverage HRA offered to employee and
spouse (not dependents) with affordability determined
using employee’s primary residence location ZIP code.
• 1U. Individual coverage HRA offered to employee and
spouse (not dependents) using employee’s primary
employment site ZIP code affordability safe harbor.
• 1V. Reserved for future use.
• 1W. Reserved for future use.
• 1X. Reserved for future use.
• 1Y. Reserved for future use.
• 1Z. Reserved for future use.
Line 15. Complete line 15 only if code 1B, 1C, 1D, 1E, 1J,
1K, 1L, 1M, 1N, 1O, 1P, 1Q, 1T, or 1U is entered on line 14
either in the “All 12 Months” box or in any of the monthly
boxes. Enter the amount of the Employee Required
Contribution, which is, generally, the employee share of
the monthly cost for the lowest-cost, self-only, minimum
essential coverage providing minimum value that is
offered to the employee. For additional details on how to
determine the Employee Required Contribution, including
how to determine the Employee Required Contribution for
the individual coverage HRA, see the Definitions section,
later. Enter the amount, including any cents. If the
employee is offered coverage but the Employee Required
Contribution is zero, enter “0.00” (do not leave blank). If
the Employee Required Contribution was the same
amount for all 12 calendar months, you may enter that
monthly amount in the “All 12 Months” box and not
complete the monthly boxes. If the Employee Required
Contribution was not the same for all 12 months (for
instance, if an ALE Member has a non-calendar year plan
and the employee share of the premium changes with the
new plan year that starts in 2025), enter the amount in
each calendar month for which the employee was offered
minimum value coverage. See the definition of Employee
Required Contribution in the Definitions section, for more
information, including on how to determine the monthly
required contribution from annual data.
Tip: For line 15, the amount entered might not be the
amount the employee is paying for the coverage, for
example, if the employee chose to enroll in more
expensive coverage, such as family coverage, or if the
14

employee is eligible for certain other healthcare
arrangements.
Line 16. For each calendar month, enter the applicable
code, if any, from Code Series 2. Enter only one code from
Code Series 2 per calendar month. The instructions below
address which code to use for a month if more than one
code from Code Series 2 could apply. If the same code
applies for all 12 calendar months, you may enter the code
in the “All 12 Months” box and not complete the monthly
boxes. If none of the codes apply for a calendar month,
leave the line blank for that month.
Code Series 2—Section 4980H Safe Harbor Codes
and Other Relief for ALE Members. An ALE Member
enters the applicable Code Series 2 indicator code, if any,
on line 16 to report for 1 or more months of the calendar
year that one of the following situations applied to the
employee.
• The employee was not employed or was not a full-time
employee,
• The employee enrolled in the minimum essential
coverage offered,
• The employee was in a Limited Non-Assessment
Period with respect to section 4980H(b),
• The ALE Member met one of the section 4980H
affordability safe harbors with respect to this employee, or
• The ALE Member was eligible for multiemployer interim
rule relief for this employee.
If no indicator code applies, leave line 16 blank. In some
circumstances, more than one indicator code could apply
to the same employee in the same month. For example,
an employee could be enrolled in health coverage for a
particular month during which they are not a full-time
employee. However, only one code may be used for a
particular calendar month. For any month in which an
employee enrolled in minimum essential coverage, in
general, indicator code 2C reporting enrollment is used
instead of any other indicator code that could also apply
(but see the exceptions to this rule below regarding the
multiemployer interim rule relief and enrollment in COBRA
continuation coverage or other post-employment
coverage). For an employee who did not enroll in health
coverage, there are some specific ordering rules for which
code to use. See the descriptions of the codes.
Note: There is no code to enter on line 16 to indicate that
a full-time employee offered coverage either did not enroll
in the coverage or waived the coverage.
• 2A. Employee not employed during the month. Enter
code 2A if the employee was not employed on any day of
the calendar month. Do not use code 2A for a month if the
individual was an employee of the ALE Member on any
day of the calendar month. Do not use code 2A for the
month during which an employee terminates employment
with the ALE Member.
• 2B. Employee not a full-time employee. Enter code 2B if
the employee is not a full-time employee for the month
and did not enroll in minimum essential coverage, if
offered for the month. Enter code 2B also if the employee
is a full-time employee for the month and whose offer of
coverage (or coverage if the employee was enrolled)
ended before the last day of the month solely because the
employee terminated employment during the month (so
Instructions for Forms 1094-C and 1095-C (2025)

that the offer of coverage or coverage would have
continued if the employee had not terminated employment
during the month).
• 2C. Employee enrolled in health coverage offered.
Enter code 2C for any month in which the employee
enrolled for each day of the month in health coverage
offered by the ALE Member, regardless of whether any
other code in Code Series 2 might also apply (for
example, the code for a section 4980H affordability safe
harbor) except as provided below. Do not enter code 2C
on line 16 for any month in which the multiemployer
interim rule relief applies (enter code 2E). Do not enter
code 2C on line 16 if code 1G is entered on line 14. Do not
enter code 2C on line 16 for any month in which a
terminated employee is enrolled in COBRA continuation
coverage or other post-employment coverage (enter code
2A). Do not enter code 2C on line 16 for any month in
which the employee enrolled in coverage that was not
minimum essential coverage.
• 2D. Employee in a section 4980H(b) Limited
Non-Assessment Period. Enter code 2D for any month
during which an employee is in a section 4980H(b)
Limited Non-Assessment Period. If an employee is in an
initial measurement period, enter code 2D (employee in a
section 4980H(b) Limited Non-Assessment Period) for the
month, and not code 2B (employee not a full-time
employee). For an employee in a section 4980H(b)
Limited Non-Assessment Period for whom the ALE
Member is also eligible for the multiemployer interim rule
relief for the month, enter code 2E (multiemployer interim
rule relief) and not code 2D (employee in a section
4980H(b) Limited Non-Assessment Period).
• 2E. Multiemployer interim rule relief. Enter code 2E for
any month for which the multiemployer arrangement
interim guidance applies for that employee, regardless of
whether any other code in Code Series 2 (including code
2C) might also apply. This relief is described under Offer
of Health Coverage in the Definitions section of these
instructions.
Note: Although ALE Members may use the section
4980H affordability safe harbors to determine affordability
for purposes of the multiemployer arrangement interim
guidance, an ALE Member eligible for the relief provided
in the multiemployer arrangement interim guidance for a
month for an employee should enter code 2E
(multiemployer interim rule relief), and not code 2F, 2G, or
2H (codes for section 4980H affordability safe harbors).
• 2F. Section 4980H affordability Form W-2 safe harbor.
Enter code 2F if the ALE Member used the section 4980H
Form W-2 safe harbor to determine affordability for
purposes of section 4980H(b) for this employee for the
year. If an ALE Member uses this safe harbor for an
employee, it must be used for all months of the calendar
year for which the employee is offered health coverage.
• 2G. Section 4980H affordability federal poverty line safe
harbor. Enter code 2G if the ALE Member used the
section 4980H federal poverty line safe harbor to
determine affordability for purposes of section 4980H(b)
for this employee for any month(s).
• 2H. Section 4980H affordability rate of pay safe harbor.
Enter code 2H if the ALE Member used the section 4980H
rate of pay safe harbor to determine affordability for

Instructions for Forms 1094-C and 1095-C (2025)

purposes of section 4980H(b) for this employee for any
month(s).
Note: An affordability safe harbor code should not be
entered on line 16 for any month that the ALE Member did
not offer minimum essential coverage, including an
individual coverage HRA, to at least 95% of its full-time
employees and their dependents (that is, any month for
which the ALE Member checked the “No” box on Form
1094-C, Part III, column (a)). For more information, see the
instructions for Form 1094-C, Part III, column (a).
• 2I. Reserved for future use.
Note: References to 9.5% in the section 4980H
affordability safe harbors and Qualifying Offer Method are
applied based on the percentage as indexed for purposes
of applying the affordability thresholds under section 36B
(the premium tax credit). The percentage, as adjusted, is
8.39% for plan years beginning in 2024, and 9.02% for
plan years beginning in 2025.
Line 17. If the ALE Member used code 1L, 1M, 1N, 1O,
1P, 1Q, 1T, or 1U because it offered the employee an
individual coverage HRA, enter the appropriate ZIP code
used for identifying the lowest cost silver plan used to
calculate the Employee Required Contribution in line 15.
This will be the ZIP code of the employee’s residence
(code 1L, 1M, 1N, or 1T) or the ZIP code of the
employee’s primary site of employment if the ALE Member
uses the work location safe harbor (code 1O, 1P, 1Q, or
1U).
Location safe harbor for individual coverage HRAs.
For purposes of section 4980H(b), an employer may use
the cost of self-only coverage for the lowest cost silver
plan for the employee for self-only coverage offered
through the Exchange where the employee’s primary site
of employment is located for determining whether an offer
of an individual coverage HRA to a full-time employee is
affordable. The ZIP code for the employee’s primary site
of employment is used to identify the applicable lowest
cost silver plan to determine affordability.
Note: In addition to the location safe harbor for individual
coverage HRAs, ALE Members may use the section
4980H affordability safe harbors to determine affordability
for purposes of section 4980H(b) for an employee for the
year.

Part III—Covered Individuals (Lines 18–30)

Note: If there are more than 13 covered individuals,
additional copies of page 3, Part III, may be used.
Complete Part III ONLY if the ALE Member offers
employer-sponsored, self-insured health coverage,
including an individual coverage HRA, in which the
employee or other individual enrolled. For this purpose,
employer-sponsored, self-insured health coverage does
not include coverage under a multiemployer plan. Do not
complete Part III if the ALE Member offers coverage only
under an insured group health plan. If an ALE Member
offers both insured and self-insured coverage, complete
Part III only for employees who enroll in the self-insured
coverage.
An ALE Member with a self-insured major medical plan
and a health reimbursement arrangement (HRA) that has
15

an individual who enrolls in both types of minimum
essential coverage is required to report the individual’s
coverage under only one of the arrangements in Part III.
An ALE Member with an insured major medical plan and
an HRA that has an individual who enrolls in both types of
minimum essential coverage is not required to report in
Part III the HRA coverage of an individual if the individual
is eligible for the HRA because the individual enrolled in
the insured major medical plan. An ALE Member with an
HRA must report coverage under the HRA in Part III for
any individual who is not enrolled in a major medical plan
of the ALE Member (for example, if the individual is
enrolled in a group health plan of another employer (such
as spousal coverage) or if the ALE Member provides an
individual coverage HRA). For additional information on
the reporting of supplemental coverage, see Proposed
Regulations section 1.6055-1(d)(2) and (3).
If the ALE Member is completing Part III, enter “X” in the
checkbox in Part III. If the ALE Member is not completing
Part III, do not enter “X” in the checkbox in Part III.
This part must be completed by an ALE Member
offering self-insured health coverage for any individual
who was an employee for 1 or more calendar months of
the year, whether full-time or non-full-time, and who
enrolled in the coverage. The employee (if enrolled in
self-insured coverage) should be listed on line 18; any
other family members who enrolled in coverage offered to
the employee should be listed on subsequent lines.
Tip: All employee family members that are covered
individuals through the employee’s enrollment (for
example, because the employee elected family coverage)
must be included on the same form as the employee (or
any other individual to whom the offer was made). For
example, if the employee is offered family coverage by
their employer under a self-insured health plan and enrolls
in the family coverage, the employee and the employee’s
family members that are covered under the plan must all
be reported on the same Form 1095-C.
If two or more employees employed by the same ALE
Member are spouses or an employee and their
dependent, and one employee enrolled in a coverage
option under the plan that also covered the other
employee(s) (for example, one employee spouse enrolled
in family coverage that provided coverage to the other
employee spouse and their employee dependent child),
the enrollment information should be reflected only on
Form 1095-C for the employee who enrolled in the
coverage. (However, it would report the other employee
family members as covered individuals.)
Coverage of nonemployee. This part may be
completed by an ALE Member offering self-insured health
coverage for any other individual who enrolled in the
coverage under the plan for 1 or more calendar months of
the year but was not an employee for any calendar month
of the year, such as a nonemployee director, a retired
employee who retired in a previous year, a terminated
employee receiving COBRA continuation coverage (or
any other form of post-employment coverage) who
terminated employment during a previous year, and a
nonemployee COBRA beneficiary (but not including an
individual who obtained coverage through the employee’s
16

enrollment, such as a spouse or dependent obtaining
coverage when an employee elects COBRA continuation
coverage that is family coverage). If Form 1095-C is used
with respect to an individual who was not an employee for
any month of the calendar year, Part II must be completed
by using code 1G in the “All 12 Months” box or the
separate monthly boxes for all 12 calendar months. The
employer must report for these individuals using Form
1095-B, if it chooses not to use Form 1095-C.
Tip: If a nonemployee individual enrolls in the coverage
under a self-insured health plan, all family members that
are covered individuals because of the individual’s
enrollment must be included on the same Form 1095-B or
Form 1095-C as the individual who is offered, and enrolls
in, the coverage.
Columns (a) through (e), as applicable, must be
completed for each individual enrolled in the coverage,
including the employee reported on line 1. Enter the
nine-digit SSN or other TIN for each covered individual in
column (b). Enter a date of birth in column (c) only if an
SSN or other TIN is not entered in column (b). Column (d)
will be checked if the individual was covered for at least 1
day in every month of the year. For individuals who were
covered for some but not all months, information will be
entered in column (e) indicating the months for which
these individuals were covered.
Tip: Governmental Unit employers offering self-insured
health coverage that have delegated another
Governmental Unit (DGE) for purposes of reporting and
furnishing enrollment information (meaning the information
that otherwise would be reported on Form 1095-C, Part
III), but have not designated a DGE for purposes of
reporting and furnishing offer of coverage information
(meaning the information that is reported on Form 1095-C,
Part II), should file and furnish Forms 1095-C with a
completed Part I and Part II, but not a completed Part III,
and should not check the box indicating that the
Governmental Unit offers self-insured health coverage. In
this case, the DGE should file Forms 1094-B and 1095-B
to report enrollment information for employees on behalf
of the Governmental Unit. See FAQs on IRS.gov.
A DGE that has been delegated by a Governmental
Unit for purposes of reporting and furnishing both offer of
coverage and enrollment information (meaning the
information that would be reported on Parts II and III of
Form 1095-C) should file Forms 1094-C and 1095-C to
report the information for employees on behalf of the
Governmental Unit.
Column (a). Enter the name of each covered individual
(first name, middle initial, last name), including the
employee, if the employee is enrolled in self-insured
coverage.
Column (b). Enter the nine-digit SSN for each covered
individual, including the dashes. For covered individuals
who are not the employee listed in Part I, a taxpayer
identification number (TIN), rather than an SSN, may be
entered if the covered individual does not have an SSN, or
the field may be left blank if the covered individual does
not have a TIN.
Instructions for Forms 1094-C and 1095-C (2025)

Column (c). Enter a date of birth (YYYY-MM-DD) for the
covered individual only if column (b) is blank.
Column (d). Check this box if the individual was covered
for at least 1 day per month for all 12 months of the
calendar year.
Column (e). If the individual was not covered for all 12
months of the calendar year, check the applicable box(es)
for the month(s) in which the individual was covered for at
least 1 day in the month.

Definitions

This section contains the definitions of key terms used in
Forms 1094-C and 1095-C and these instructions. For
definitions of terms not included in this section, see the
final regulations under section 4980H, T.D. 9655, 2014-9
I.R.B. 541, at IRS.gov/irb/2014-9_IRB/ar05.html and
section 6056, T.D. 9661, 2014-13 I.R.B. 855, at
IRS.gov/irb/2014-13_IRB/ar09.html.
Affordability. Generally, the lowest cost silver plan for the
employee based on the employee’s residence is used to
determine affordability. The ZIP code for the employee’s
residence is used to identify the applicable lowest cost
silver plan to determine affordability.
Aggregated ALE Group. An Aggregated ALE Group
refers to a group of ALE Members treated as a single
employer under section 414(b), 414(c), 414(m), or 414(o).
An ALE Member is a member of an Aggregated ALE
Group for a month if it is treated as a single employer with
the other members of the group on any day of the
calendar month. If an ALE is made up of only one person
or entity, that one ALE Member is not a part of an
Aggregated ALE Group. Government entities and
churches or conventions or associations of churches may
apply a reasonable, good faith interpretation of the
aggregation rules under section 414 in determining their
status as an ALE or member of an Aggregated ALE
Group. For more information on how the aggregation rules
apply to government entity employers, see Notice
2015-87, Q&A 18, at IRS.gov/irb/2015-52_IRB/ar11.html.
Applicable Large Employer (ALE). An ALE is, for a
particular calendar year, any single employer, or group of
employers treated as an Aggregated ALE Group, that
employed an average of at least 50 full-time employees
(including full-time equivalent employees) on business
days during the preceding calendar year. For purposes of
determining an employer’s average number of employees,
disregard an employee for any month in which the
employee has coverage under a plan described in section
4980H(c)(2)(F) (generally, TRICARE or Veterans
Administration coverage). A new employer (that is, an
employer that was not in existence on any business day in
the prior calendar year) is an ALE for the current calendar
year if it reasonably expects to employ, and actually does
employ, an average of at least 50 full-time employees
(including full-time equivalent employees) on business
days during the current calendar year. For information on a
special rule for certain employers with seasonal workers,
see the final regulations under section 4980H and FAQs
on IRS.gov.

Instructions for Forms 1094-C and 1095-C (2025)

Applicable Large Employer Member (ALE Member).
An ALE Member is a single person or entity that is an
ALE, or if applicable, each person or entity that is a
member of an Aggregated ALE Group. A person or entity
that does not have employees or only has employees with
no hours of service (for example, only employees whose
entire service consists of work outside of the United
States that does not count as hours of service under
section 4980H) is not an ALE Member.
Bona fide volunteer. A bona fide volunteer is an
employee of a government entity or tax-exempt
organization whose only compensation from that entity or
organization is (1) reimbursement for (or reasonable
allowance for) reasonable expenses incurred in the
performance of services by volunteers, or (2) reasonable
benefits (including length of service awards), and nominal
fees, customarily paid by similar entities in connection with
the performance of services by volunteers.
COBRA continuation coverage. COBRA continuation
coverage is health coverage that is required to be offered
under the Consolidated Omnibus Budget Reconciliation
Act of 1986 (COBRA) in certain circumstances in which
an employee or other individual covered under a health
plan loses eligibility for coverage under that health plan
(for example, because the employee terminates
employment or has a reduction in hours). For purposes of
these instructions, COBRA continuation coverage also
includes coverage required under any other federal or
state law that provides continuation coverage comparable
to that provided under COBRA. For additional details, see
section 4980B and Regulations sections 54.4980B-1
through 54.4980B-10.
Dependent. A dependent is an employee’s child,
including a child who has been legally adopted or legally
placed for adoption with the employee, who has not
reached age 26. A child reaches age 26 on the 26th
anniversary of the date the child was born and is treated
as a dependent for the entire calendar month during which
they reach age 26. For this purpose, a dependent does
not include stepchildren, foster children, or a child that
does not reside in the United States (or a country
contiguous to the United States) and who is not a U.S.
citizen or national. For this purpose, a dependent does not
include a spouse.
Designated Governmental Entity (DGE). A DGE is a
person or persons that are part of or related to the
Governmental Unit that is the ALE Member and that is
appropriately designated for purposes of these reporting
requirements. For a Governmental Unit that has delegated
some or all of its reporting responsibilities to a DGE for
some or all of its employees, one Authoritative Transmittal
must still be filed for that Governmental Unit reporting
aggregate employer-level data for all employees of the
Governmental Unit (including those for whom the
Governmental Unit has delegated its reporting
responsibilities). For more information, see Authoritative
Transmittal for Employers Filing Multiple Forms 1094-C,
earlier.
Eligible employer-sponsored plan. An eligible
employer-sponsored plan refers to group health coverage
for employees under (1) a governmental plan, such as the
17

Federal Employees Health Benefits Program (FEHB); (2)
an insured plan or coverage offered in the small or large
group market within a state; (3) a grandfathered health
plan offered in a group market; or (4) a self-insured group
health plan for employees, including an individual
coverage HRA.
Employee. An employee is an individual who is an
employee under the common-law standard for
determining employer–employee relationships. An
employee does not include a sole proprietor, a partner in a
partnership, an S corporation shareholder who owns at
least 2% of the S corporation, a leased employee within
the meaning of section 414(n), or a worker that is a
qualified real estate agent or direct seller.
If an employee is an employee of more than one ALE
Member of the same Aggregated ALE Group during a
calendar month, the employee is treated as an employee
of the ALE Member for whom the employee has the
greatest number of hours of service for that calendar
month; if the employee has an equal number of hours of
service for two or more ALE Members of the same
Aggregated ALE Group for the calendar month, those ALE
Members must treat one of the ALE Members as the
employer of that employee for that calendar month. See
One Form 1095-C for Each Employee of Each Employer
for a discussion of reporting in these circumstances. See
Pub.15-A, Employer’s Supplemental Tax Guide, for more
information on determining who is an employee.
Note: In certain circumstances, an employee may have a
break in service (including a break in service due to a
termination of employment) during which the individual
does not earn hours of service but, upon beginning to
earn hours of service again, the ALE Member must treat
the individual as a continuing employee rather than a new
hire for purposes of certain rules under the regulations
under section 4980H. See Regulations sections
54.4980H-3(c)(4) and 54.4980H-3(d)(6). These rules do
not impact whether the individual was an employee during
the break in service, so the individual should only be
treated as an employee during the break in service for
purposes of reporting if the individual remained an
employee during that period (and had not terminated
employment with the ALE Member). For example, an
employee on unpaid leave during the break in service
would be treated as an employee for reporting purposes
during the break in service, while a former employee
whose employment had been terminated during the break
in service would not be treated as an employee for
reporting purposes.
Employee Required Contribution. The Employee
Required Contribution is the employee’s share of the
monthly cost for the lowest-cost, self-only minimum
essential coverage providing minimum value that is
offered to the employee by the ALE Member. The
employee share is the portion of the monthly cost that
would be paid by the employee for self-only coverage,
whether paid through salary reduction or otherwise.
For purposes of determining the amount of the
employee’s share of the monthly cost, an ALE Member
may divide the total cost to the employee for the plan year
by the number of months in the plan year. This monthly
18

amount of the employee’s share of the cost would then be
reported for any months of that plan year that fall within
the 2025 calendar year. For example, if the plan year
begins January 1, the ALE Member may determine the
amount to report for each month by taking the total annual
employee cost for all 12 months and dividing by 12. If the
plan year begins April 1, the ALE Member may determine
the amount to report for January through March 2025, by
taking the total annual employee cost for the plan year
ending March 31, 2025, and dividing by 12 (and reporting
that amount for January, February, and March 2025).
Then, the ALE Member may determine the monthly
amount for April through December 2025 by taking the
total annual employee cost for the plan year ending March
31, 2025, and dividing by 12 (and reporting that amount
for April through December 2025).
The Employee Required Contribution may not be the
amount the employee paid for coverage. For additional
rules on determining the amount of the Employee
Required Contribution, including for cases in which an
ALE Member makes available certain HRA contributions,
cafeteria plan contributions, wellness program incentives,
and opt-out payments, see Regulations sections
1.5000A-3(e)(3)(ii) and 1.36B-2(c)(3)(v)(A). Also see
Notice 2015-87.
Special rules apply for individual coverage HRAs.
Generally, the Employee Required Contribution for the
individual coverage HRA means the required HRA
contribution, as defined in Regulations section 1.36B-2(c)
(5)(ii). However, for purposes of the individual coverage
HRA safe harbors in Proposed Regulations section
54.4980H-5(f), the required contribution is determined
based on the applicable lowest cost silver plan, as defined
in Proposed Regulations 54.4980H-5(f)(7)(iii), and the
monthly premium for the applicable lowest cost silver plan
is determined based on the employee’s age, as defined in
Proposed Regulations 54.4980H(f)(7)(i), and the
employee’s applicable location, as defined in Proposed
Regulations 54.4980H(f)(7)(ii).
For an employee offered an individual coverage HRA,
the Employee Required Contribution is the excess of the
monthly premium for the applicable lowest cost silver plan
based on the employee’s applicable age over the monthly
individual coverage HRA amount (generally, the annual
individual coverage HRA amount divided by 12).
Applicable lowest cost silver plan. Generally, the
lowest cost silver plan for an employee for a calendar
month is the lowest cost silver plan for self-only coverage
of the employee offered through the Exchange for the ZIP
code of the employee’s applicable location for the month.
If there are different lowest cost silver plans in different
parts of a rating area, an employee’s applicable lowest
cost silver plan is the lowest cost silver plan in the part of
the rating area in which the employee’s applicable location
is located. The lowest cost silver plan for an employee is
the lowest cost silver plan for the lowest age band in the
individual market for the employee’s applicable location.
For more information, see Employer Lowest Cost Silver
Plan Premium Look-up Table.
Applicable age. For an employee who is or will be
eligible for an individual coverage HRA on the first day of
the plan year, the employee’s applicable age for the plan
Instructions for Forms 1094-C and 1095-C (2025)

year is the employee’s age on the first day of the plan year.
For an employee who becomes eligible during the plan
year, the employee’s applicable age for the remainder of
the plan year is the employee’s age on the date the
individual coverage HRA can first become effective for
that employee. Note that for non-calendar year plans or for
employees who become eligible during the plan year, the
applicable age may not be the age reported in Part II of
Form 1095-C.
Applicable location. An employee’s applicable
location is where the employee resides for the calendar
month, or if the ALE Member is applying the location safe
harbor, the employee’s primary site of employment for the
calendar month.
Employer. For purposes of these instructions, an
employer is the person that is the employer of an
employee under the common-law standard for
determining employer–employee relationships and that is
subject to the employer shared responsibility provisions of
section 4980H (these employers are referred to as ALE
Members). For more information on which employers are
ALE Members, see the definitions of Applicable Large
Employer (ALE) and Applicable Large Employer Member
(ALE Member).
Full-time employee. For purposes of Forms 1094-C and
1095-C, the term “full-time employee” means a full-time
employee, as defined under section 4980H and the
related regulations, rather than any other definition of that
term that the ALE Member may use for other purposes.
Accordingly, a full-time employee is an employee who, for
a calendar month, is determined to be a full-time
employee under either the monthly measurement method
or the look-back measurement method (as applicable to
that employee). The monthly measurement method and
the look-back measurement method are the two methods
provided under the section 4980H regulations for
determining whether an employee has sufficient hours of
service to be a full-time employee. Under the monthly
measurement method, a full-time employee is an
employee who was employed an average of at least 30
hours of service per week with the ALE Member during a
calendar month. Under the look-back measurement
method, an employee is a full-time employee for each
month of the stability period selected by the ALE Member
if the employee was employed an average of at least 30
hours of service per week with the ALE Member during
the measurement period preceding that stability period.
(The look-back measurement method for identifying
full-time employees is available only for purposes of
determining and computing liability under section 4980H,
and not for purposes of determining if the employer is an
Applicable Large Employer.) For purposes of both
methods, 130 hours of service in a calendar month is
treated as the monthly equivalent of at least 30 hours of
service per week.
An ALE Member must report complete information for
all 12 months of the calendar year for any of its employees
who were full-time employees for 1 or more months of the
calendar year. For more information on the identification of
full-time employees, including discussion of the monthly
measurement method and the look-back measurement
method, and the rules for when an ALE Member may use
Instructions for Forms 1094-C and 1095-C (2025)

one or both methods, see Regulations sections
54.4980H-1(a)(21) and 54.4980H-3, and Notice 2014-49,
2014-41 I.R.B. 66 (describing a proposed approach to the
application of the look-back measurement method in
situations in which the measurement period applicable to
an employee changes).
Note: A former employee (for example, a retiree) is not a
full-time employee for any month after termination of
employment with the ALE Member. However, if the former
employee was a full-time employee for any month of the
calendar year (for example, before retiring mid-year), the
ALE Member must complete information in Part II of Form
1095-C for all 12 months of the calendar year, using the
appropriate codes.
Tip: An ALE Member need not file a Form 1095-C for an
individual who for each month of a calendar year is either
not an employee of the ALE Member or is an employee in
a Limited Non-Assessment Period with respect to section
4980H(b). However, for the months in which the employee
was an employee of the ALE Member, such an employee
would be included in the total employee count reported on
Form 1094-C, Part III, column (c). Also, if during the
Limited Non-Assessment Period the employee enrolled in
coverage under a self-insured, employer-sponsored plan,
the ALE Member must file a Form 1095-C for the
employee to report coverage information for the year.
Full-time equivalent employees. A combination of
employees, each of whom individually is not treated as a
full-time employee because they are not employed on
average at least 30 hours of service per week with an
employer, but who, in combination, are counted as the
equivalent of a full-time employee solely for purposes of
determining whether the employer is an ALE. For rules on
how to determine full-time equivalent employees, see
Regulations section 54.4980H-2(c).
Governmental Unit and Agency or Instrumentality of
a Governmental Unit. A Governmental Unit is the
government of the United States, any state or political
subdivision thereof, or any Indian tribal government (as
defined in section 7701(a)(40)) or subdivision of an Indian
tribal government (as defined in section 7871(d)). For
purposes of these instructions, references to a
Governmental Unit include an Agency or Instrumentality of
a Governmental Unit. Until guidance is issued that defines
the term “Agency or Instrumentality of a Governmental
Unit” for purposes of section 6056, an entity may
determine whether it is an Agency or Instrumentality of a
Governmental Unit based on a reasonable and good faith
interpretation of existing rules relating to agency or
instrumentality determinations for other federal tax
purposes.
Health coverage. As used in these instructions, health
coverage refers to minimum essential coverage, unless
otherwise indicated.
Hours of service. An hour of service is each hour for
which an employee is paid, or entitled to payment, for the
performance of duties for the employer, and each hour for
which an employee is paid, or entitled to payment, for a
period of time during which no duties are performed due
to vacation, holiday, illness, incapacity (including
19

disability), layoff, jury duty, military duty, or leave of
absence. An hour of service does not include any hour of
service performed as a bona fide volunteer of a
government entity or tax-exempt entity, as part of a
Federal Work-Study Program (or a substantially similar
program of a state or political subdivision thereof) or to the
extent the compensation for services performed
constitutes income from sources outside the United
States. For additional rules for determining hours of
service, see Regulations sections 54.4980H-1(a)(24) and
54.4980H-3(b), and Notice 2015-87, Q&A 14, at
IRS.gov/irb/2015-52_IRB#NOT-2015-87. See section VI of
the preamble to the section 4980H regulations for a
discussion of determination of hours of service for
categories of employees for whom the general rules for
determining hours of service may present special
difficulties (including adjunct faculty and commissioned
salespeople) and certain categories of work hours
associated with some positions of employment, including
layover hours (for example, for certain airline employees),
on-call hours, and work performed by an individual who is
subject to a vow of poverty as a member of a religious
order.
Individual coverage HRA. An HRA is a type of
account-based health plan that employers can use to
reimburse employees for their medical care expenses. An
individual coverage HRA is an HRA integrated with
individual health insurance coverage or Medicare, subject
to certain conditions. For more information about
individual coverage HRAs, see T.D. 9867 and IRS.gov/
Newsroom/Health-Reimbursement-Arrangements-HRAs.
Limited Non-Assessment Period. A Limited
Non-Assessment Period generally refers to a period
during which an ALE Member will not be subject to an
assessable payment under section 4980H(a) and, in
certain cases, section 4980H(b), for a full-time employee,
regardless of whether that employee is offered health
coverage during that period.
The first 5 periods described below are Limited
Non-Assessment Periods with respect to sections
4980H(a) and 4980H(b) only if the employee is offered
health coverage by the first day of the first month following
the end of the period. Also, the first 5 periods described
below are Limited Non-Assessment Periods for section
4980H(b) only if the health coverage that is offered at the
end of the period provides minimum value. For more
information on Limited Non-Assessment Periods and the
application of section 4980H, see Regulations section
54.4980H-1(a)(26).
• First year as ALE period. January through March of the
first calendar year in which an employer is an ALE, but
only for an employee who was not offered health coverage
by the employer at any point during the prior calendar
year.
• Waiting period under the monthly measurement
method. If an ALE Member is using the monthly
measurement method to determine whether an employee
is a full-time employee, the period beginning with the first
full calendar month in which the employee is first
otherwise (but for completion of the waiting period) eligible
for an offer of health coverage and ending no later than 2

20

full calendar months after the end of that first calendar
month.
• Waiting period under the look-back measurement
method. If an ALE Member is using the look-back
measurement method to determine whether an employee
is a full-time employee and the employee is reasonably
expected to be a full-time employee at their start date, the
period beginning on the employee’s start date and ending
not later than the end of the employee’s third full calendar
month of employment.
• Initial measurement period and associated
administrative period under the look-back measurement
method. If an ALE Member is using the look-back
measurement method to determine whether a new
employee is a full-time employee, and the employee is a
variable hour employee, seasonal employee, or part-time
employee, the initial measurement period for that
employee and the administrative period immediately
following the end of that initial measurement period.
• Period following change in status that occurs during
initial measurement period under the look-back
measurement method. If an ALE Member is using the
look-back measurement method to determine whether a
new employee is a full-time employee, and, as of the
employee’s start date, the employee is a variable hour
employee, seasonal employee, or part-time employee,
but, during the initial measurement period, the employee
has a change in employment status such that, if the
employee had begun employment in the new position or
status, the employee would have reasonably been
expected to be a full-time employee, the period beginning
on the date of the employee’s change in employment
status and ending not later than the end of the third full
calendar month following the change in employment
status. If the employee is a full-time employee based on
the initial measurement period and the associated stability
period starts sooner than the end of the third full calendar
month following the change in employment status, this
Limited Non-Assessment Period ends on the day before
the first day of that associated stability period.
• First calendar month of employment. If the employee’s
first day of employment is a day other than the first day of
the calendar month, then the employee’s first calendar
month of employment is a Limited Non-Assessment
Period.
Minimum essential coverage (MEC). Although various
types of health coverage may qualify as MEC, for
purposes of these instructions, MEC refers to health
coverage under an eligible employer-sponsored plan. An
individual coverage HRA is a self-insured group health
plan and an eligible employer sponsored plan. For more
details on MEC, see Minimum essential coverage in Pub.
974.
Minimum value. A plan provides minimum value if the
plan pays at least 60% of the costs of benefits for a
standard population and provides substantial coverage of
in-patient hospitalization services and physician services.
An individual coverage HRA that is affordable is treated as
providing minimum value.
Offer of health coverage. An ALE Member makes an
offer of coverage to an employee if it provides the
employee an effective opportunity to enroll in the health
Instructions for Forms 1094-C and 1095-C (2025)

coverage (or to decline that coverage) at least once for
each plan year. For this purpose, the plan year must be 12
consecutive months unless a short plan year of less than
12 consecutive months is permitted for a valid business
purpose. An ALE Member makes an offer of health
coverage to an employee for the plan year if it continues
the employee’s election of coverage from a prior year but
provides the employee an effective opportunity to opt out
of the health coverage. If an ALE Member provides health
coverage to an employee but does not provide the
employee an effective opportunity to decline the coverage,
the ALE Member is treated as having made an offer of
health coverage to the employee only if that health
coverage provides minimum va

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3Aaeb7a31009e88072. Public record. Not legal advice.