Who Must Receive a 1095-C: Three Employee Groups Explained

Executive overview

Many employers file 1095-Cs for the wrong employees — or miss ones they're required to cover. The ACA rule is simpler than it appears. If an employee was ACA full-time for at least one month in the year, they get a 1095-C. If never full-time, they don't.

Full-time means averaging 30+ hours per week or 130+ hours per month. Job title, salary type, and exempt/non-exempt status are irrelevant.

Measuring full-time status

• Monthly measurement method: review hours month by month.
• Look-back method: assess hours over a longer window (typically 6–12 months); designed for employees with fluctuating or seasonal hours.
• Employers prefer look-back because it creates stability — eligibility doesn't flip on and off.

The three employee groups that cause confusion

• Terminated employees: if full-time for even one month during the year, file a 1095-C regardless of when they left.
• Part-time employees: those who were full-time for at least one month (including employees who shifted from full-time to part-time) receive a 1095-C; true part-timers who were never full-time do not.
• Employees who declined coverage: enrollment status is irrelevant; the IRS cares about the offer, not the acceptance.