Self-Funded Companies and ACA Compliance

If a company operates a self-funded (also known as “self-insured”) health plan for its employees and is an Applicable Large Employer (ALE) or part of an Aggregated Applicable Large Employer (AALE), Zenefits will also need to collect information about any dependents that enrolled in coverage during the filing year, including any prior plans that were active for any part of the year.

If a company has a non-calendar plan year in place (i.e., does not start in January), then the company likely had at least two different plans during the filing year (one before the renewal date, and one after). In that case, the company will need to provide dependent information for the current plan year as well as the previous plan year (which started in the previous year and ran into the current year).

If a company is an ALE or part of an AALE, and offered self-funded health plans, the company is only required to provide Form 1095-C to its employees. Else, the company will need to provide one Form 1095-B to each eligible employee, and provide copies of those Forms 1095-B to the IRS along with a Form 1094-BZenefits ACA Compliance app will allow administrators to automatically complete Forms 1094-C and 1095-C. Zenefits will not generate or file Forms 1094-B  or 1095-B.

Note: Please reach out to your Zenefits Customer Success Manager, if applicable, or the Customer Support team, if you are offering self-funded plans to your employees. There will be an additional step required, to include dependent enrollment information for ACA reporting purposes. Your Zenefits team will guide you. Please do not send out 1095-C forms to employees without completing the additional step.


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