ACA Year-End: 1095-C Dependent Forms

How to create, populate, and finalize 1095-C dependent forms for self-insured employers

***Note: If you are returning to review your 1095-C data AFTER processing your 1094-C Employer Form, you must un-finalize, re-populate, and re-finalize your 1094-C Employer Form.

Dependent Forms 1095-C

A Dependent Form 1095-C should be used when an Applicable Large Employer (ALE) needs to issue a Form 1095-C to an individual not listed in the system. An example of this would be an individual who is no longer eligible to be covered under an employee’s plan enrolling in COBRA with an ALE that offers self-insured coverage. This could be an ex-spouse after a divorce or
a dependent child who has passed the eligibility age. In these situations, Forms 1095-C do not have to be provided to such individuals if the COBRA coverage is fully insured. Should there be a question as to whether to issue a Form 1095-C or not, please contact your insurance provider or benefit broker.

Companies have the option to create a Dependent Form 1095-C for employee dependents who are considered nonemployees and who, along with the employee, were enrolled in a self-insured healthcare plan.

Note: This option will only be available for companies who are COBRA self-insured and have checked the Enable COBRA reporting for self-insured health plan setting in the ACA Settings widget under Settings > Global Setup > Company Setup.

Additionally, the employee’s ACA Profile should contain both the COBRA Reporting Active Employees and COBRA Reporting Terminated Employees rules.

Creating 1094-C Dependent Form

1. From your ACA Year-End Checklist, click on "View dependent forms 1095-C:"
2. Click the "Add New" button on the top right.
3. From here, you can manually type in all data for the dependent form, or you can click the Populate Form button for a helpful questionnaire.

Populating 1094-C Dependent Form

1. When adding a new Form 1095-C Dependent for an individual and then populating the form using the Populate Form button, a 1095C Questionnaire Confirmation pop-up will display. The pop-up provides instructions on how to manually complete the form or edit an existing form. To create a form for COBRA reporting, select COBRA Reporting as the reason for the 1095-C.
2. 
3. Selecting the Individual already has a form 1095-C for this reporting year option will display additional instructions.If creating the form for a non-employee dependent, use the second option, Individual listed in part I of the form was enrolled in COBRA for at least one month in the reporting year.
4. When you select "Yes" from the COBRA plan is Self-Insured drop-down list, youcan select the month(s) in which the non-employee dependent was enrolled.
5. After the dependent's settings are selected in the questionnaire, the form will be generated and populated.
   1. Part I and Part III of the form should be checked for accurate information and potential manual editing. Validation will be performed upon saving.
   2. The dependent’s name, address, and social security number will need to be entered manually on the form.
   3. In Form 1094-C for the reporting year, the totals in Part 1, Line 18, and Part II, Line 20 will need to be adjusted to include the number of Dependent Forms 1095-C. The number of 1095-C Dependent forms can be determined from the Forms 1095-C Dependent report. 
6. After all information is complete and correct, the form can be saved, finalized, and downloaded as a PDF.
7. Use the Back icon on the top left to get back to the Year-End Process.
8. Click “Mark as Complete” next to the 1095-C Dependent - create, populate, and finalize (optional) Step.