ALE payroll, benefits and ACA reporting reviewers

1095-C Monthly Reporting Review for Payroll and Benefits Teams

Build the evidence behind each employee-month before approving Form 1095-C. This site focuses on reporting decisions and source reconciliation, including offers, required contributions, applicable line 16 treatment and self-insured enrollment.

Create a complete employee-month record

Start with the legal employer, reporting year and employee's relevant history. Keep employment status, offers, plan terms and actual enrollment as separate facts. The 2025 C-series instructions define the reporting fields and applicable code rules.

A current benefits screen may miss an earlier offer, termination or coverage change. Preserve the effective dates and the source owner for each event. Do not infer that an employee who waived enrollment had no offer, or that an enrolled employee had the same offer all year.

Give lines 14, 15 and 16 separate evidence

Line 14 describes the offer using the applicable Series 1 code. Line 15 reports the employee required contribution when the code and instructions require it. For a traditional group offer, the relevant value is the lowest-cost self-only minimum-value option available to the employee, rather than automatically the employee's chosen family-plan deduction.

Line 16 reflects the applicable Series 2 treatment, with rules for competing circumstances and code priority. Review the line-specific instructions together. A blank can be correct; filling every month with a familiar safe-harbor code is not a substitute for evidence.

Review a fictional midyear premium change

Fictional Harbor Vale's reviewed lowest-cost self-only minimum-value option costs an employee $96 monthly through June and $108 from July through December. Assume the reviewed offer codes require line 15 for every month. The worksheet therefore retains six months at $96 and six at $108.

The employee elected family coverage with a larger deduction, but that elected-plan cost does not replace the reviewed line 15 source. The team inspects the six changed months in the generated form and prevents an all-year $96 value from surviving the plan change.

Keep ICHRA locations and actual coverage distinct

Line 17 applies to specified individual coverage HRA offer codes and the ZIP code used to identify the relevant lowest-cost silver plan. It is not triggered by line 16 code 2G, which is the federal poverty line safe harbor. The 2025 line 17 instructions identify the applicable residence or work-location use.

Part III reports covered individuals for applicable employer-sponsored self-insured coverage. Do not populate it merely because the employer made an insured-plan offer. Reconcile actual enrolled people and coverage months independently of the Part II offer history, using the instructions' coverage and supplemental-arrangement rules.

Choose a practical guide

Use the practical guide library below for the next step. Each guide includes a worked example, a diagram and a downloadable worksheet.

Questions from reporting teams

Can payroll deductions supply every line 15 amount?

Only when the reviewed source actually measures the required contribution for the applicable offer. The employee's elected coverage tier may have a different cost.

Does a waiver mean line 14 should show no offer?

No. Verify what coverage was offered and when. Election and offer records answer different questions.

Is line 17 a ZIP-code field for safe harbor 2G?

No. Code 2G concerns the federal poverty line safe harbor. Line 17 has its own ICHRA-specific conditions tied to the applicable Series 1 codes.

What should a month-level review retain?

Keep the effective dates, source facts, selected treatment, contribution calculation where required and reviewer decision. Identify the generated version that reflects those conclusions.

Put reviewed employee-month data to work

Create a BoomTax account to begin your organization's filing setup. Keep the reporting year, expected return volume and reviewed source records available as you prepare the project.