Troubleshooting: Why wasn't a 1095 form generated for my employee(s)?

There are several factors that go into determining who should receive a 1095 form.  Use the following scenarios to troubleshoot any employees who do not have a form generated, but that you expected to receive a form, particularly when their ACA classification was Eligible.

Applicable Large Employer (ALE)

Small Group Employer

 

 Applicable Large Employer (ALE)

Company Settings

Employee Classifications

Terminated Employees

Statutory Classifications

Retirees

COBRA

Collectively Bargained Employees (Union)

Dependents

Variable Hour Employees

Limited Non-Assessment Period Employees

Company Settings

 Your Part 1 Employer Information needs to indicate that you are an ALE. 

• Navigate to ACA > 1094/1095 Reporting > Part 1 Employer Information 
• Check the box for Question 2 “Are you a large employer (ALE)?"
• Select Save at the bottom of the page.
• Return to step 3 of the Audit (ACA > 1094/1095 Reporting > Audit and E-File > 3 Preview Form Data)
• Select Create Preview of Form Data to regenerate the forms.

Employee Classifications

Terminated Employees:

If an employee has been terminated <30 days from their hire date or with <30 days of employment in 2018, they will not receive a form. An employee will receive a form in 2018 if they are terminated in January of 2018 but are offered coverage until the end of the month. Check the individual employee’s hire and termination dates to validate the duration of their employment in 2018.

• Employees > find employee by last name > Profile > Employment 
• Review Hire Date and Termination Date

Statutory classifications:

Statutory classified employees will not receive a form if they are enrolled in a fully insured plan. Statutory classifications include:

• Sole Proprietor
• Partner in a Partnership
• 2% shareholder of a S corporation
• Bona Fide Volunteer
• Federal Work Study
• Direct lineal descendent to a S Corp Shareholder
• Non-employee

To troubleshoot:

• Verify that an employee is not marked with a statutory classification (Employee > find employee by last name > Profile > Employment > Statutory Class > Select the class in the dropdown box 

Retirees:

If an employee is retired and was enrolled in a self-funded plan in 2018, they will receive a form. 

• Verify that they are marked as retired and the retired date is correct
• Retiree enrollment information must be available from the enrollment or import history

COBRA:

If an employee is enrolled in a COBRA self-funded plan for 2018, they will receive a form.

• Verify the enrollment information including plan and dates on the COBRA dashboard
• There is no need to indicate that it is a COBRA enrollment
• NOTE:  If the employee is enrolled in a COBRA fully insured plan, they will not receive a form if they were terminated with less than 30 days of employment in 2018
• NOTE:  The final Instructions for Forms 1094-C and 1094-B indicate that only COBRA participants in a self-funded plan require a form.  The IRS has outdated information on their web site that is superseded by the final instructions.  

Union:

If an employee is part of a collective bargaining group (union employee), verify the following:collectively bargained needs to be set on the employee's profile.

• Collectively bargained is set on the employee's profile (Employees > Find Employees by last name > Profile > Is Collectively Bargained? > Yes)
• The ee is in a non-benefit eligible class.
• If the employer is contributing to the union plan, then MEWA information needs to be selected (Part 1 Employer Information > Select Question 3: For collectively bargained (union) employees, are you required to  contribute to a multiple employer welfare arrangement?)

Dependents:

If an employee has dependents on a self-funded plan, the 1095C for each employee will reflect any dependents enrolled in a plan.  (NOTE:  dependent information is not required for fully insured plans)

• Verify the enrollment information for dependents including dates

Variable Hour:

If an employee is listed as a variable hour employee, check the following:

• Verify that you have Set Measurement Periods correctly
• Verify that hours are completed for the Measurement Period for each employee
• ACA > ACA console > Manage Employees > Missing Hours
• Select any Period Missing Hours for an individual employee to be brought to the specific period that is missing hours.

Limited Non-Assessment Period Employees:

According to the Instructions for Forms 1094-C and 1095-C:  "An employer 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 employer or is an employee in a Limited Non-Assessment Period."  As a result, Employee Navigator will not generate a form for any employee in a Limited Non-Assessment Period.

NOTE:  The instructions also indicate that " An employer offers health coverage for a month only if it offers health coverage that would provide coverage for every day of that calendar month."  Employees who completed their limited non-assessment period in December 2018 may have been offered coverage for part of December, but as coverage would not meet the "every day of the calendar month" standard as above, these employees would not receive a form because their Line 14 and 16 codes would still reflect a limited non-assessment period for December.

Small Group

For small groups, only those employees and dependents (self-funded) who are enrolled in coverage for more than 30 days in 2018 will receive a form.

• Verify the enrollment information including dates

 

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