Line 14 on Form 1095-C uses IRS Series 1 codes to show what type of health coverage an employer offered to an employee for each month of the year.
What is Line 14 on Form 1095-C?
Line 14 is labeled Offer of Coverage.
It tells the IRS:
Whether health coverage was offered
What type of coverage was offered
Who the offer was made to
Which months the offer applied
A Line 14 code must be entered for each month, or once in the “All 12 Months” column if the same code applies for the full year.
What do Line 14 codes represent?
Line 14 codes are IRS Series 1 codes that describe the employer’s offer of coverage.
These codes generally indicate:
No offer of coverage
A traditional employer-sponsored coverage offer
An Individual Coverage HRA (ICHRA) offer
Whether the offer applied to the employee only, spouse, dependents, or a combination
Line 14 codes do not show whether the employee enrolled in coverage. They only show what coverage was offered.
What Line 14 codes are commonly used for ICHRA?
ICHRA offers use specific Line 14 codes.
Common ICHRA Line 14 codes include:
1L — ICHRA offered to employee only using residence ZIP code
1M — ICHRA offered to employee and dependents using residence ZIP code
1N — ICHRA offered to employee, spouse, and dependents using residence ZIP code
1O — ICHRA offered to employee only using primary worksite ZIP code safe harbor
1P — ICHRA offered to employee and dependents using primary worksite ZIP code safe harbor
1Q — ICHRA offered to employee, spouse, and dependents using primary worksite ZIP code safe harbor
1R — ICHRA offered but not affordable
1T — ICHRA offered to employee and spouse using residence ZIP code
1U — ICHRA offered to employee and spouse using primary worksite ZIP code safe harbor
These codes show that the employer offered individual health insurance coverage through an HRA instead of a traditional group health plan.
What does Line 14 code 1H mean?
Code 1H means no offer of coverage.
Use 1H when:
No health coverage was offered for the month
The employee was not eligible for benefits that month
The coverage offered was not Minimum Essential Coverage (MEC)
Code 1H is commonly used for months when an employee was not benefits-eligible.
How do Line 14 ICHRA codes affect affordability reporting?
Line 14 ICHRA codes help identify how affordability should be evaluated.
Affordability may depend on:
The employee’s residence ZIP code
The employee’s primary worksite ZIP code
Whether the employer uses an available safe harbor
The ICHRA monthly allowance
The applicable lowest-cost silver plan premium
Line 14 does not determine affordability by itself. It must be reviewed with Line 15 and Line 16.
How is Line 14 different from Line 15 and Line 16?
Line 14, Line 15, and Line 16 serve different ACA reporting purposes.
Line 14 shows what coverage was offered.
Line 15 shows the employee required contribution, when applicable.
Line 16 shows the applicable safe harbor, enrollment status, or reason the employer may not owe a penalty.
Line 14 alone does not determine Marketplace premium tax credit eligibility or employer penalty exposure.
Can Line 14 codes change month to month?
Yes. Line 14 codes can change during the year.
Codes may change if:
An employee becomes newly eligible for coverage
An employee loses eligibility
Employment status changes
Benefit class changes
Coverage starts or ends mid-year
An ICHRA offer changes
The employee terminates employment
Each month should accurately reflect the coverage offer for that specific month.
What should I do if a Line 14 code looks incorrect?
If a Line 14 code appears incorrect:
Verify the employee’s eligibility for the month.
Confirm whether an ICHRA or group health plan was offered.
Review employment status changes.
Check benefit class assignments.
Confirm whether the correct residence or worksite ZIP code methodology was used.
Consult your payroll, tax, or compliance advisor before filing corrections.
Incorrect Line 14 codes may affect ACA reporting accuracy.
Does Take Command provide tax or legal advice?
No. Take Command provides ACA reporting support and platform data, but does not provide legal, tax, or accounting advice.
Employers should consult a qualified tax professional, CPA, attorney, or compliance advisor for questions about ACA reporting obligations or Form 1095-C corrections.