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Administrator Guide
Last Updated: 2024-05-03
Reference: Affordable Care Act 1095-C Form Codes

Reference: Affordable Care Act 1095-C Form Codes

This page provides a quick reference to 1095-C code explanations, taken from the IRS Instructions for Forms 1094-C and 1095-C. The
Workday Tips
 column provides quick reference information and additional information.
Seek the advice of your legal counsel regarding any concerns or differences in interpretation, as you’re ultimately responsible for Affordable Care Act (ACA) compliance. Customers who need to report different codes (due to differences in interpretation, edge cases Workday doesn't support, or any other reason) need to load those codes using the
Import 1095-C Form Recipient Data
 EIB.
Line 14: Offer of Coverage
Line 14 defines who was offered coverage and what type of coverage you offered. The codes apply when the offer of coverage is for all days of the month. Fill in this line for every month. Specify these values on the benefit plan definition:
  • Plan funding type.
  • Minimum value coverage and minimum essential coverage for employee, spouse, and dependents.
  • Conditional spousal coverage.
Code
Explanation
Workday Tips
1A
Qualifying offer includes these coverages and costs:
  • Minimum essential coverage providing minimum value offered to full-time employees.
  • The lowest cost for employee-only coverage is equal to or less than 9.5% (as adjusted) of the mainland single federal poverty line.
  • Minimum essential coverage offered to spouse and dependents.
Affordable coverage for only the employee and coverage for a spouse and dependents.
Don’t populate cost on line 15 if using this code.
The IRS instructions note that the adjusted percentage is 9.61% for plan years beginning in 2022, and 9.12% for plan years beginning in 2023 (p. 13).
Workday research indicates that the 2022 poverty line of $13,590 applies to coverage offered in the 2023 tax year. Thus affordable care is equal to or less than $103.28 per month, for employee only coverage.
Enter the poverty line and adjusted percentage value on the Affordable Care Reporting Configuration page.
1B
Minimum essential coverage providing minimum value offered to the employee only.
Employee only
1C
Minimum essential coverage providing minimum value offered to the employee and at least minimum essential coverage offered to dependents (not spouses).
Employee + dependents (not spouse)
1D
Minimum essential coverage providing minimum value offered to the employee and at least minimum essential coverage offered to spouse (not dependents). Don’t use code 1D if you offer the coverage for the spouse conditionally. Instead use code 1J.
Employee + spouse (no dependents)
1E
Minimum essential coverage providing minimum value offered to the employee and at least minimum essential coverage offered to dependents and spouse. Don’t use code 1E if you offer the coverage for the spouse conditionally. Instead use code 1K.
Employee + dependents and spouse
1F
Minimum essential coverage
not
 providing minimum value offered to the employee; employee and spouse or dependents; or employee, spouse, and dependents.
Cost of employee-only coverage doesn’t meet affordability standard.
1G
Offer of coverage for at least 1 month to an individual who doesn't meet 1 or more these conditions:
  • An employee for any month of the year.
  • An employee who wasn’t a full-time employee for any month of the year and was enrolled in self-insured coverage 1 or more months of the year. This period might include 1 or more months in which the individual wasn’t an employee.
Part-time employees or retirees in self-insured coverage.
1G applies to the entire year or not at all.
1H
No offer of coverage. You didn't offer the employee health coverage or you offered employee-offered coverage that:
  • Isn’t minimum essential coverage.
  • Might include one or more months in which the individual wasn’t an employee.
1I
Reserved. Not applicable for TY2023.
1J
Minimum essential coverage providing minimum value offered to the employee and at least minimum essential coverage conditionally offered to spouse; minimum essential coverage not offered to dependents.
Employee + spouse with conditional coverage (no dependents)
1K
Minimum essential coverage providing minimum value offered to the employee; at least minimum essential coverage offered to dependents; and at least minimum essential coverage conditionally offered to spouse.
Employee + dependents and spouse with conditional coverage
1L
Individual coverage HRA (ICHRA) offered only to the employee. Affordability based on ZIP code of employee's primary residence.
ICHRA for an employee only. Affordability based on employee residence. Workday doesn't derive this code. Load with the EIB.
1M
ICHRA offered to the employee and dependents (not spouse). Affordability based on ZIP code of employee's primary residence.
ICHRA for the employee + dependents (not spouse). Affordability based on employee residence. Workday doesn't derive this code. Load with the EIB.
1N
ICHRA offered to the employee, spouse, and dependents. Affordability based on ZIP code of employee's primary residence.
ICHRA for the employee + dependents and spouse. Affordability based on employee residence. Workday doesn't derive this code. Load with the EIB.
1O
ICHRA offered only to the employee. Using employee's primary employment site ZIP code affordability safe harbor.
ICHRA for an employee only. Affordability based on employee work site safe harbor. Workday doesn't derive this code. Load with the EIB.
1P
ICHRA offered to the employee and dependents (not the spouse). Using employee's primary employment site ZIP code affordability safe harbor.
ICHRA for the employee + dependents (not spouse). Affordability based on employee work site safe harbor. Workday doesn't derive this code. Load with the EIB.
1Q
ICHRA offered to the employee, spouse, and dependents. Using employee's primary employment site ZIP code affordability safe harbor.
ICHRA for the employee + dependents and the spouse. Affordability based on employee work site safe harbor. Workday doesn't derive this code. Load with the EIB.
1R
ICHRA that is
not
 affordable and offered to any of these combinations of covered individuals:
  • Employee only
  • Employee + Spouse/Partner
  • Employee + Dependent
  • Employee + Spouse + Dependent
ICHRA not affordable. Workday doesn't derive this code. Load with the EIB.
1S
ICHRA offered to an individual that isn’t a full-time employee.
ICHRA offered to an individual that isn't a full-time employee. Workday doesn't derive the code. Load with the EIB.
Line 15: The employee's share of the lowest-monthly cost for employee-only coverage that you offered.
Line 15 answers the question: What was the cost of the offered coverage?
If the lowest employee-only coverage offered doesn’t meet the affordability standard, enter the lowest monthly cost. Populate this line only if one of these codes is in line 14:
  • 1B
  • 1C
  • 1D
  • 1E
  • 1J
  • 1K
Enter 0.00 if employee cost is zero. Don't leave it blank.
Line 16: Applicable Section 4980H Safe Harbor
Line 16 answers these questions:
  • Did the employee enroll in coverage?
  • If the employee wasn't offered coverage, why not?
If the worker waived coverage and there are no applicable safe harbors, line 16 can be blank.
To apply the safe harbors:
  1. Create a 4980H Safe Harbor Eligibility Rule to identify which workers the safe harbor provision (or provisions) applies to.
  2. Create ACA 4980H Safe Harbor Configuration to designate the specific safe harbor provisions for the reporting year and apply the eligibility rules as appropriate.
You can use affordability safe harbors to determine affordability based on the interim guidance for multiemployer arrangements. Use code 2E if the employer is eligible for the relief provided in the interim guidance for multiemployer arrangements.
Code
Explanation (IRS Text)
Workday Tips
2A
The person isn't an employee for any day during the month. Don’t use this code if the person was an employee on any day in the month, including the month in which you hired or terminated the employee.
Not employed.
2B
Employee isn’t a full-time employee. Enter code 2B if:
  • Employee isn’t full time for the month and didn’t enroll in minimum essential coverage, if offered for the month
  • Employee is full time for the month. The offer of coverage (or coverage, if enrolled) ended before the last day of the month because they terminated during the month. Otherwise, the coverage, or offer of coverage, would have continued.
Not full-time.
For a month in which you terminated the employee before the last day, Workday:
  • Automatically derives the codes 1H and 2B.
  • Derives the codes applicable at termination if both:
    • The employee's coverage extends to the end of the month.
    • You select the
      Use coverage end date in month of termination
       check box on the 1094-C Company Configuration.
For subsequent months, even if you extend the coverage after termination, the codes are 1H/2A.
2C
You employ and enroll the employee for all days of the month. Use regardless of whether any other code could apply (except for 2E).
Don’t use 2C:
  • 2C if 1G is applicable for full year on line 16 because the employee wasn’t full time for any month.
  • For any month that an employee was in COBRA or other postemployment coverage (use code 2A).
  • For any month in which the multiemployer interim rule relief applies (enter code 2E).
  • For any month in which a terminated employee enrolls in COBRA continuation coverage or other postemployment coverage (use code 2A).
  • For any month in which the employee enrolled in coverage that wasn’t minimum essential coverage.
Enrolled in medical coverage.
2D
Employee in Limited Non-Assessment Period (regardless of whether employee is full-time or part-time). If employee is in LNAP AND employer is eligible for multiemployer interim rule relief for the month, use 2E.
In waiting period (LNAP).
2E
Multiemployer interim rule relief. For any month in which the interim guidance for multiemployer arrangements applies for the employee, regardless of whether any other code might apply.
Multiemployer interim rule relief
2F
Employer used the section 4980H Form W2 safe harbor to determine affordability for purposes of section 4980H(b) for this employee for the year. If you use this safe harbor for an employee, use it for all months of the calendar year during which the employee is offered health coverage.
Section 4980H affordability Form W-2 safe harbor
2G
Employer used the section 4980H federal poverty line safe harbor to determine affordability for purposes of section 4980H(b) for this employee for any months.
Section 4980H affordability federal poverty line safe harbor
2H
Employer used the section 4980H rate of pay safe harbor to determine affordability for purposes of section 4980H(b) for this employee for any months.
Section 4980H affordability rate of pay safe harbor
2I
Reserved. Not applicable for TY2023.
Line 17: ZIP Codes for ICHRA Participants
When using ICHRA codes in Line 14, enter the ZIP code of the employee's residence, or the primary work site when using the work location safe harbor. Workday doesn’t derive these ZIP codes. Load them with the Import 1095-C Form Recipients Data EIB spreadsheet.