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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 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. Part III of the 1095-C form needs to be completed if the employee had dependents enrolled on the self-funded plan.

From ACA filing year 2022 onwards, if the enrolled dependent information is available within Zenefits, the ACA Compliance app will automatically pull this information into the employees' 1095-C forms. The company admin using the ACA  Compliance app will need to mark at least one plan as "self-funded" within the ACA app, when prompted in the filing flow. The enrolled dependent(s) data for the employees enrolled in those plans, will be added to Part III of their  1095-C forms. The admin will be able to review the dependent data on the forms and also edit the data if required.

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 review, and provide if required, 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-B. Zenefits 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: Coverage through COBRA is not considered within the Zenefits ACA Compliance app.

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