The Biggest Challenges of Affordable Care Act Reporting

Written by Adam Miller, HR Compliance Manager, Passport Software, Inc.

Affordable Care Act

I’ve helped hundreds of Applicable Large Employers (ALEs) manage their Affordable Care Act requirements and file their 1094-C/1095-Cs. Though each had different reporting needs, the same question kept coming up…

How do I complete Part 2?

1095-C Part II
The original source: https://www.irs.gov/pub/irs-pdf/f1095c.pdf

Lines 14, 15, and 16 make up Part 2 of the 1095-C and provide details of an employer’s offer of coverage to a full-time employee. Knowing how to correctly complete this section is imperative for Affordable Care Act compliance and avoiding penalties.

Line 14—Use code 1E.

Choosing a line 14 code requires you to know three things:

  • Was coverage offered?
  • Did it meet minimum standards?
  • Was it available to the spouse and dependents?

Deciding on the best 1A-1K code to complete line 14 has one extra nuance, and it can save you hours of scrutiny: If a full-time employee is offered coverage and has the unconditional option to add their spouse and dependents to their plan, you may use the corresponding 1E code for all employees offered coverage—even those who are not married or do not have children. Since spouse or dependent coverage doesn’t need to meet any cost standards, there is little reason not to offer it.

With this allowance, most fully ACAcompliant companies will find they can use Line 14 code 1E for every 1095-C they submit, instead of 1B for single employees, 1C for single parents, and 1D for childless couples. Your life is already easier, isn’t it?

Line 15—Forget about Line 14.

This continues to be a very tough concept to nail down. The IRS wants to know: What is the monthly employee’s share of the least expensive, employee-only plan available to this person?

Let’s review each part of that statement.

  • Employee’s share—the employee’s remaining portion after the employer’s contribution.
  • Least expensive—the qualifying plan with the lowest monthly cost available, often referred to as bronze level. This is not what the employee is paying for a more comprehensive plan.
  • Employee only—One Person. Forget that on Line 14 you reported that the offer included the spouse/dependents. For the purposes of ACA reporting, it does not matter which plan an employee actually enrolls in, only what they could have chosen and what it would have cost them.

Line 16—What happened after Line 14?

It isn’t difficult to find that code 2C applies to employees who accept an offer of coverage, or that 2B is used for a part-time employee. Things start to get murky with code 2D. Code 2D refers to the variable-hour[i] employee who is in their Initial Measurement Period, also known as the Look-Back Method.

People start to panic when it comes to employees who were offered insurance but declined. In their 1095-C Instructions, the IRS wrote 1181 words describing all the Series 2 Codes in use. Nowhere does it say “Use code __ if the employee declined coverage.” In cases where you have made an a fully qualified offer which an employee has turned down, use whichever of 2F/2G/2H matches your method for calculating their income and ensuring affordability:

  • Use 2F if you look at W-2 Wages
  • Use 2G if you use the Federal Poverty Level
  • Use 2F if you look at the employee’s Rate of Pay

Congratulations…

Not only have you completed Part 2, but unless your company self-insures, you can bypass Part 3 completely!

What’s the next step?

Knowing how to correctly use the codes and contribution fields is fundamental, but organized tracking of ACA-related information throughout the year is equally important to save time and avoid penalties. A good, regularly maintained spreadsheet is a serviceable option for smaller ALEs with straightforward ACA reporting. For larger employers, or more complicated reporting, a specially designed software solution or service will reduce the compliance workload and help avoid penalties. A good one will help you accurately manage changing and editing data and even create the 1094-C/1095-C forms or electronic files.

Passport Software’s ACA Software and Services range from on-premise software to full year-round compliance management services. Our friendly service is fast and accurate, and our customers have given us great reviews. Our software is IRS-certified and we are IRS-approved to file on behalf of our clients.

Dealing with past years reporting troubles? We can help there, too.

Learn more about Passport Software’s ACA Software and Services, or call us at 800-969-7900.

[i] variable-hour refers to cases where it is unclear whether the employee will be comfortably above or below the 130 hour per month full-time threshold.

Form 1095-C
The original source: https://www.irs.gov/pub/irs-pdf/f1095c.pdf

About the Author:

Adam Miller

Adam Miller is the HR Compliance Manager at Passport Software, Inc. He designed their ACA Software and, as a support tech, he has helped hundreds of people with Affordable Care Act compliance and reporting.  Adam has a background in engineering, the service industry, and print, which makes him a technically proficient and friendly communicator for Passport Software.

Passport Software, Inc.

181 North Waukegan Rd, #200

Northfield, IL 60093

800-969-7900

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