Do Dependents/Spouse Need to Be Reported on 1095-C Forms?
Points North • May 14, 2019

Employees will oftentimes wonder why Part III of their 1095-C form doesn’t contain any information. This is because Part III of the form is used only to track individuals (employee, dependents, spouse, retirees, employees on continuation coverage, non-employees, etc.) covered under an employer-sponsored self-insured plan.
The instructional line for Part III that appears directly on the 1095 form is actually quite specific, stating: “If Employer provided self-insured coverage, check the box and enter the information for each individual enrolled in coverage, including the employee.” The full instructions for the 1095-C form get even more detailed, stating: “Complete Part III ONLY if the ALE Member offers employer-sponsored, self-insured health coverage 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.”
So while it may seem like something is missing from your form if Part III is completely blank, remember that per the instructions, that section is intended to be left empty unless you’re reporting on employer-sponsor self-insured health coverage.
The instructional line for Part III that appears directly on the 1095 form is actually quite specific, stating: “If Employer provided self-insured coverage, check the box and enter the information for each individual enrolled in coverage, including the employee.” The full instructions for the 1095-C form get even more detailed, stating: “Complete Part III ONLY if the ALE Member offers employer-sponsored, self-insured health coverage 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.”
So while it may seem like something is missing from your form if Part III is completely blank, remember that per the instructions, that section is intended to be left empty unless you’re reporting on employer-sponsor self-insured health coverage.
Disclaimer: The information provided within is for general informational purposes only. It does not necessarily address all of your specific questions or issues. It should not be construed as, nor is it intended to provide, legal advice. Questions regarding specific issues and application of these rules to your 1095-C reporting should be addressed by your legal counsel.

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