The Hidden Traps of Self‑Insured 1095‑C Reporting

If your company self-insures, an employee who was never full-time will still need a complete 1095‑C if they were enrolled in that self-insured coverage (instructions, pg 2). Not a 1095‑B, but the full C form, with a specific code, filled out a specific way. Most ACA software misses this because it’s built to answer one question — did you offer coverage to full-time employees — and self-insurance quietly adds a second one that doesn’t care about full-time status at all.

Two different jobs on one form

A 1095‑C has a primary job. Parts I and II answer the employer-mandate question under §4980H: did this ALE offer affordable, minimum-value coverage to this full-time employee, month by month. That’s the part everyone knows.

Self-insured employers have a second, unrelated job: report everyone who was actually covered. Normally that’s the insurance carrier’s job, done separately on Form 1095‑B. But with self-insurance, the employer is the coverage provider, and that duty lands on Part III of the same 1095‑C instead of a standalone form.

Part III doesn’t ask about full-time status (instructions, pg 16). It asks who had coverage, and in which months — full-time, part-time, variable-hour, or in some cases, not an employee at all.

The rule that catches people

The consequence: an employee who was never full-time — someone who, under Part II alone, would never generate a 1095‑C at all — still needs one if they enrolled in the self-insured plan. Their form carries no ordinary employer-mandate offer codes. Line 14 uses code 1G for the entire year, and Part III lists everyone the coverage actually covered: the employee, plus any spouse or dependents also enrolled.

Miss this, and the employer hasn’t failed to offer coverage — they’ve failed to report coverage they actually provided. That’s its own, separate compliance gap, easy to have with an otherwise-perfect employer-mandate filing.

Where 1G trips people up

• It’s all-or-nothing for the year

  Unlike every other Line 14 code, 1G doesn’t vary month to month. Use it for all twelve months or not at all (instructions, pg 13) — there’s no partial-year version.

• One full-time month disqualifies it

  1G is only for someone who was never full-time (or never an employee) for the whole year (instructions, pg 2). The moment they have even one full-time month, the form reverts to ordinary Part II offer-code logic for the whole year.

• Don’t pair it with Line 16 code 2C

  Everywhere else, an offer code pairs with a Line 16 code showing what happened — enrolled, safe harbor, and so on. Not here: Part III already reports the enrollment, so adding 2C duplicates it (instructions, pg 15) and is treated as an error, not a belt-and-suspenders extra.

• The employee is their own covered individual

  It’s easy to fill in a spouse and kids in Part III and skip the employee — but their own enrollment belongs there too, typically the first line (instructions, pg 16).

• It isn’t limited to current employees

  Someone on COBRA, or a retiree still enrolled in the self-insured plan (instructions, pg 2), isn’t an active employee at all — and can still need this same reporting.

• More than 13 covered individuals require a continuation page

  A large family on one self-insured plan can outgrow the standard Part III grid (instructions, pg 15). Software that doesn’t generate the continuation page silently drops people instead of flagging it.