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
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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.
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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.
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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.
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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).
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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.
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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.
Why this gets missed
Most ACA tooling is built around the Part II employer-mandate question, because that’s the headline compliance concern and the one tied to the big ESRP penalties. Full-time tracking becomes the trigger for "does this person need a form" — which is correct for Part II and silently wrong for Part III, because the self-insured trigger doesn’t check full-time status at all. A system built to ask only one question will never ask the other.