Articles & E-Books


Coding of Forms 1095-C: Common Scenarios

May 24, 2016

We’ve heard from many of our clients that the first two years of preparing Form 1095-C for reporting under the Affordable Care Act was less than smooth. Reporting of Form 1095-C is required to indicate offers of health insurance coverage and affordability safe harbors. Coding of the forms, however, can be confusing.


To fulfill the IRC Section 6056 requirement, Forms 1094-C and 1095-C are to be used by applicable large employers (ALE), which are those with 50 or more full-time employees (FTE), including full-time-equivalent employees, in the preceding calendar year. Form 1094-C is used for transmitting Form 1095-C. Self-insured ALEs will combine Sections 6055 and 6056 reporting on Form 1095-C.

Coding: The Challenge

When leveraging software to prepare the forms 1095-C, most solutions lack preprogrammed intelligence to input proper codes. The appropriate codes are based on a number of input factors, factors that can differ month to month for each employee. The result is a time-consuming, manual process.

Wipfli assisted a number of our clients with reporting of Forms 1094-C and 1095-C, including the preparation and coding of their Forms 1095-C. Our team has compiled a list of the most common scenarios and their respective coding that we saw this past reporting year -Affordable Care Act: Scenarios for Form 1095-C Reporting

If you have not already filed your forms with the IRS (paper filing is due May 31; electronic filing is due June 30), you may leverage this tool as you review your coding to help avoid issues. Otherwise, we hope you find this information helpful in streamlining your Form 1095-C coding in the future. Should you need additional assistance with preparing your forms, please contact Pam Branshaw or your Wipfli relationship executive.