Line 14 of Form 1095-C uses IRS “Series 1” codes to show what type of health coverage an Applicable Large Employer (ALE) offered to an employee each month, including whether coverage was offered, who it was offered to, and whether it was an Individual Coverage HRA (ICHRA) offer.
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What is Line 14 on Form 1095-C?
Line 14 is titled “Offer of Coverage.”
It tells the IRS:
Whether the employer offered health coverage
What type of coverage was offered (MEC, ICHRA, etc.)
Who the coverage was offered to (employee, spouse, dependents)
Which months the offer applied
A code must be entered for every month (or once for all 12 months if the same code applies).
What do Line 14 codes represent?
Each Line 14 code is a two-character IRS code (Series 1) that describes the employer’s offer of coverage.
In general, these codes fall into three categories:
No offer or non-qualified offer
Traditional employer-sponsored coverage offers
ICHRA (Individual Coverage HRA) offers
Line 14 codes do not indicate whether an employee enrolled in coverage—only whether coverage was offered.
What Line 14 codes are used for ICHRA?
If you are offering an ICHRA, Line 14 will use specific ICHRA-related codes:
ICHRA offer codes (common examples)
1L – ICHRA offered to employee only (residence ZIP used for affordability)
1M – ICHRA offered to employee + dependents (no spouse)
1N – ICHRA offered to employee + spouse + dependents
1O – ICHRA offered using primary worksite ZIP affordability safe harbor (employee only)
1P – ICHRA offered to employee + dependents (worksite ZIP safe harbor)
1Q – ICHRA offered to employee + spouse + dependents (worksite ZIP safe harbor)
1R – ICHRA offered but not affordable (any family combination)
1T – ICHRA offered to employee + spouse only (residence ZIP)
1U – ICHRA offered to employee + spouse only (worksite ZIP)
These codes are used to show that an employee was offered individual coverage through an HRA instead of a traditional group plan.
What does code 1H mean?
1H means: No offer of coverage.
It is used when:
No health coverage was offered for that month, or
Coverage offered was not Minimum Essential Coverage (MEC), or
The employee was not offered any qualifying employer coverage
This code is often used for months when an employee is not eligible for benefits.
How do ICHRA codes affect affordability reporting?
Some Line 14 codes (like 1L–1Q) are paired with affordability methods that the IRS uses to determine:
Whether the ICHRA is considered affordable
Whether the employee may still qualify for Premium Tax Credits
Whether employer mandate penalties may apply
Affordability is determined separately using employee ZIP code or worksite ZIP code safe harbors.
How does Line 14 differ from Line 15 and Line 16?
Line 14 → What coverage was offered
Line 15 → Employee contribution amount (if applicable)
Line 16 → Why coverage applies or does not apply (safe harbor, enrollment, employment status)
Line 14 alone does not determine tax credit eligibility—it must be read with Lines 15 and 16.
Do Line 14 codes change month to month?
Yes. Employers may use different codes across the year if:
An employee’s eligibility changes
Coverage is added or removed mid-year
The employee moves between benefit classes
Employment status changes (full-time vs part-time, termination, etc.)
An employee becomes newly eligible for an ICHRA
Each month must accurately reflect the offer status for that period.
What if I think my Line 14 code is incorrect?
If a Line 14 code looks incorrect:
Verify employee eligibility for that month
Confirm whether an ICHRA or group plan was offered
Check employment status changes during the year
Review benefit class assignments
Consult your payroll or tax advisor before filing corrections
Incorrect codes can affect ACA reporting accuracy and IRS compliance.