Question of the Month: January 2021

Question: For reporting 2020 coverage on the 1095-C, does the “plan start month” field in Section II refer to the starting month of the employer’s plan or the month coverage begins for an employee?

Answer: This field, which is mandatory for the first time in 2020, is looking for the employer’s group medical plan year. It is not referring to when the employee may join the plan.

Employers should enter a two-digit number corresponding to the first calendar month of the plan year under which the employee was offered coverage (or would have been offered coverage if the employee were eligible). This will be the same code for all Forms 1095-C, as an employer’s group health plan year does not vary based on the timing of individual employee enrollment. For example, an employer with a calendar year medical plan should use 01 on all forms. And an employer with a July – June plan year would use 07 on all forms.

The instructions indicate that if there is more than one plan year that could apply (e.g., if an employer changed the plan year during the year), then the earliest applicable month should be used. For example, if an employer switched its plan year from 2/1 to 8/1, the employer should use a two-digit code corresponding to the earlier of the two plan years (02) for all Forms 1095-C. In cases where no health plan is offered, the employer should enter 00.