Insight to Action

Benefits & Healthcare Update: IRS Publishes Final 2015 Instructions for Health Insurance Information Reporting

1 October 2015

On September 18, 2015, the Internal Revenue Service (IRS) published the final 2015 instructions for completing Forms 1094-C and 1095-C. The 2015 instructions clarify the reporting of multiemployer plan coverage, make a substantive change in the manner in which offers of COBRA coverage are reported, and clarify how employers report HRA coverage paired with insured medical benefits. The Form 1095-C is due to individuals by January 31, 2016, and all Forms 1095-C and the Form 1094-C is due to the IRS by March 31, 2016.

Multiemployer Plan Reporting

Employers with employees covered by multiemployer or union plans should use code 1H (no offer of coverage) on Line 14 and code 2E (multiemployer interim rule relief) on Line 16 for any month that the employer contributed to the multiemployer plan on behalf of an employee receiving the Form 1095-C. To complete the Forms 1095-C for employees covered by multiemployer plans, the employer needs to know which employees are full-time according to the ACA and whether or not the employer contributed to the fund on behalf of those employees; employers do not need to know whether those employees are actually covered by the multiemployer plan.


An offer of COBRA coverage made to a former employee upon termination of employment is not reported as an offer of coverage on Line 14. Instead, employers enter code 1H (no offer of coverage) on line 14 and code 2A (individual not employed) on line 16 for any month for which a COBRA offer was made to a terminated employee after the month of termination.


A large employer that maintains a fully-insured group health plan and an integrated HRA does not fill out Form 1095-C, Part III for employees covered by the HRA and the employer’s group health plan. Employers complete Part III for HRA coverage only when the employee is covered by the HRA and another group major medical plan (such as a spouse’s).

The final instructions are available at:

Questions and answers from the IRS about health insurance information reporting are available online at:

If you have any questions regarding health insurance information reporting, please contact Ed Doherty at 646-839-8251 or via email at