SmartFusion Modules -> Human Resources -> Insurance And Benefits -> Reports -> IRS Forms 1094-C and 1095-C

Report Header

VOID checkbox (always blank)
CORRECTED checkbox (user report selection)

PART 1 Employee Info

Boxes 1-6 pull from the employee data on "Payroll Enter/Edit Employee Master -> General Tab"

Box 1 Name of employee
Box 2 Social security number (SSN)
Box 3 Street address (including apartment no.)
Box 4 City or town
Box 5 State or province
Box 6 Country and ZIP or foreign postal code

Boxes 7-13 pull from organization system settings

Box 7 Name of employer
Box 8 Employer identification number (EIN)
Box 9 Street address (including room or suite no.)
Box 10 Contact telephone number
Box 11 City or town
Box 12 State or province
Box 13 Country and ZIP or foreign postal code

PART 2 Employee Offer

Plan Start Month (Enter 2-digit number) is Left blank.

Configuration Note: The Plan start month will be a required field for 2016 coverage reporting. Benefit start and stop dates will be required on employee benefits to report the 2016 reporting year.

Box 14 Offer of Coverage
This is the "IRS Benefit Offer Code" added to employee-benefit details in the Enter/Edit Insurance and Benefits Master window. The IRS Benefit offer code will be filled out based on the start and end dates of the Benefits.

FOR each complete month of coverage (based on the benefit effective and end dates), enter the code set by users

FOR each partial month of coverage and each month of no coverage fill in code 1H

IF the offer code is the same for all 12 months
THEN print the offer code in the "All 12 months" box and don't print the monthly boxes.

Employees may have multiple benefit codes in the reporting period with different benefit offer codes. When employees are double covered for the whole month, the first benefit's offer code is used.

Configuration Note: COBRA  
Currently SmartFusion requires a separate benefit to track COBRA coverage to employees since there is no COBRA status on the employee-benefit relationship. There is a COBRA flag for dependants and those will be reported accordingly for dependents that qualify for COBRA where employees do not. This may be revised in 2016 after the 2015 reporting period

Code Series 1

1A. Qualifying Offer: Minimum essential coverage providing minimum value offered to full-time employee with employee contribution for self-only coverage equal to or less than 9.5% mainland single federal poverty line and at least minimum essential coverage offered to spouse and dependent(s).
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)).
1E. Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to dependent(s) and spouse.
1F. Minimum essential coverage NOT providing minimum value offered to employee, or employee and spouse or dependent(s), or employee, spouse and dependents.
1G. Offer of coverage to employee who was not a full-time employee for any month of the calendar year and who enrolled in self-insured coverage for one or more months of the calendar year.
1H. No offer of coverage (employee not offered any health coverage or employee offered coverage that is not minimum essential coverage).
1L. Qualifying Offer Transition Relief 2015: Employee (and spouse or dependents) received no offer of coverage, received an offer that is not a qualifying offer, or received a qualifying offer for less than 12 months.

Box 15 Employee Share of Lowest Cost Monthly Premium, for Self-Only Minimum Value Coverage

FOR each month in which codes; 1B, 1C, 1D, or 1E are entered in box 14

Fill in the employee-benefit attribute value "minimum employee only contribution amount" of the benefit the employee had that month

Also

IF the value of the "minimum employee contribution amount" is the same for all 12 months
THEN fill in the value in the "all 12 moths box instead of the monthly boxes

Configuration Note: It is the user's responsibility to calculate the correct MEC amount, for each employee, to report outside of SmartFusion, as there is no way to calculate this value with existing SmartFusion data.

Employees may have multiple benefit codes with different "minimum employee contribution amounts" in different months (there is no IRS documented guidance on how to handle these edge cases). When employees are double covered for the whole month, the first benefit's "minimum employee contribution amount" value is used.

Box 16 Applicable Section 4980H Safe Harbor (enter code, if applicable)

Code Series 2:

2A - Employee not employed during the month (calculated from payroll employee attributes)
2B - Employee not a full-time employee (calculated with employee type OR hours test)
2C - Employee enrolled in coverage offered (based on IRS benefit offer code settings)
2D - Employee in a section 4980H(b) Limited Non-Assessment Period (calculated from payroll employee attributes)
2E - Multiemployer interim rule relief (new benefit attribute - CSWISFIB-68)
2F - Section 4980H affordability Form W-2 safe harbor (new employee-benefit attribute - CSWISFIB-69)
2G - Section 4980H affordability federal poverty line safe harbor (new employee-benefit attribute - CSWISFIB-69)
2H - Section 4980H affordability rate of pay safe harbor (new employee-benefit attribute - CSWISFIB-69)
2I - Non-calendar year transition relief applies to this employee (not supported - see design assumptions)

Unlike Code Series 1 for "benefit offer types" which have clear exclusive tests, code series 2 has a convoluted interdependent selection priority.

FOR each employee,

FOR each month

GIVEN an employee has a benefit with the "multiemployer arrangement benefit" as True
THEN code 2E
ELSE ...

What constitutes a "Full Time" employee?

Active employees with employee type of "Salaried"
OR
Active employees with employee type of "Blank, Daily, Hourly, or Leave of Absence" that worked an average of 130 hours or more for the calendar month, for each whole calendar month they are employed.

GIVEN an employee has a benefit for the entire month

AND the "Declined offer of Coverage" is unchecked in the employee-benefit detail
AND the employee is a "Full Time" employee

THEN code 2C
ELSE ...

GIVEN an employee was not employed at all during the month
THEN code 2A
ELSE ...

GIVEN the employee was employed for part of the month (starting or ending) employment
THEN code 2D
ELSE ...

GIVEN the month is January

AND the benefit start date is before the employee's first payroll date in January

THEN code 2B
ELSEIF

GIVEN an employee is not a "Full Time" employee for the month

AND the employee "Declined offer of Coverage"

OR

GIVEN an employee is a "Full Time" employee for the month

AND the employee was terminated

THEN code 2B
ELSE ...

Troubleshooting 'Full Time Employees'
  • For hourly Employees the Payroll Labor History Report shows an employees hours on each check by date.
  • For Salary Employees check the employee edit history on the Payroll Enter/Edit Employee Master. If there is a gap between the employee's start date and the available edit history, SmartFusion will use the nearest history record to determine the employee type.

GIVEN user selection of the W-2 Safe Harbor
AND the 2F test is true (see IRS Safe Harbor Codes)
THEN code 2F

GIVEN user selection of the Pay Rate Safe Harbor
AND the 2H test is true (see IRS Safe Harbor Codes)
THEN code 2H

GIVEN user selection of the Federal Poverty Line Safe Harbor
AND the 2G test is true (see IRS Safe Harbor Codes)
THEN code 2G 

Configuration Notes: Safe Harbor Codes

1. The safe harbor's must be uniformly applied on an individual employee

2. They do not have to be uniformly applied to all employees (can be applied in groups)

3. The W-2 Safe Harbor (2G) DOESNT apply to an employee if the employee contribution varies from pay period to pay period

4. The Pay Rate Safe Harbor (2H) DOESNT apply to an employee if the hourly/salary rate goes down during the period

Best Practice: Pick a single safe harbor to use for the entire organization

Alternate Practice: Decide how to segment employees for each safe harbor with the report selection filters, then run a 1094/5-C batch for each Safe Harbor.

The Federal Register details the 2F 2G and 2H safe harbors here: http://www.gpo.gov/fdsys/pkg/FR-2014-02-12/pdf/2014-03082.pdf pp. 8599

PART 3 Covered Individuals

GIVEN an employee has a heath benefit in the reporting year with the "employer-sponsored self-insured health plan" checked

AND the "decline offer of coverage" is unchecked

AND the "multiemployer arrangement benefit" is unchecked

AND the employee-benefit 'Decline Offer of Coverage' is unchecked

THEN fill in part III

AND check the covered individuals checkbox

ELSE leave blank

Boxes 17-34

Covered individuals (employee and dependents) are ordered alphabetically by last name.

  • (a) Name of covered individual(s) - Employee or Dependent's Name

  • (b) SSN - Employee or Dependent's SSN

  • (c) DOB (If SSN is not available, else blank) - Employee or Dependent's DOB

  • (d) Covered all 12 months

    IF the individual was covered for at least one day per month for all 12 months of the calendar year.
    THEN check box d

The dependent's benefit start & stop dates will be used if available. Otherwise, the employee-benefit start and stop dates to calculate will be used if the dependent dates are blank.

  • (e) Months of Coverage

    IF d is false
    THEN check the applicable box(es) for the months in which the individual was covered for at least one day in the month

Reference Material

IRS Forms 1094-C and 1095-C
IRS Instructions: https://www.irs.gov/pub/irs-pdf/i109495c.pdf
IRS 1095-C Sample: https://www.irs.gov/pub/irs-pdf/f1095c.pdf