Wednesday, June 29, 2016

Reporting Offers of Coverage on Your ACA Return

Welcome to an unofficial part two for frequently asked questions on offers of coverage and how to report them for Applicable Large Employers (ALEs). Since the rest of what’s reported on a 1094-C or 1095-C is your standard identifying information (name, address, SSN, etc.), we’ve found most of the questions we answer on the ExpressACAForms support lines have to do with reporting the offers of coverage codes.

It makes perfect sense: this is the first year anyone is dealing with these Affordable Care Act forms and codes. So let’s get started with answering the questions you have.

How should an ALE report an offer of coverage made to an employee for a specific calendar month?
To report an offer of coverage made to an employee, an ALE will use line 14 of Form 1095-C, under Part II, Offer of Coverage. Consult the offer of coverage codes to see which code best defines the offer provided for the employee for whom you’re filing this Form 1095-C. If one code applied for all 12 months of the year, you could enter it in the first box, “All 12 Months” and leave the remainder of line 14 blank. However, if you need to report an offer code for one or more specific months, you’ll just put the code in the appropriately marked box(es), Jan-Dec.

How should an ALE report the offer of coverage for the first month an employee was hired?
For the first month an employee was hired, ALEs should enter code 1H (no offer of coverage) unless the employee was offered (and accepted) coverage that applied each day of the month, even if they began work on a later day than the first. Keep in mind, though, that ALEs who use code 1H for the first month of employment may be entitled to relief under section 4980H liability if limited non-assessment period conditions apply. But more on that later.

How should an ALE report the offer of coverage for the last month a recipient was employed?
Like the first month of hire, unless your offer of coverage (or the coverage itself) extends to every day of the month someone’s employment was terminated, you’ll enter code 1H on line 14 for their last month. If the offer of coverage would have extended to the last day of the month had the employee not terminated his/her employment, you’ll still need to enter code 1H, however, you’ll be eligible for relief under section 4980H liability. You can indicate this by entering code 2B on line 16 for that month.

Are ALEs required to enter a code on line 16 of Form 1095-C?
No. The codes entered on line 16 of Form 1095-C indicate certain situations for employees (as in, their first or last month) or the type of safe harbor relief an ALE is eligible for under section 4980H. If any of the codes for line 16 apply for the employee for whom you’re filing, you’ll need to enter them in the appropriate month(s). Otherwise, you can leave line 16 blank.

E-filing with ExpressACAForms
Time is running out to e-file with ExpressACAForms before the ACA e-filing deadline tomorrow, June 30, 2016. If you need help with your account or have any questions about your forms, give us a call between 9:00 a.m. and 6:00 p.m. ET at (704) 839-2270. If you need us after hours, we provide 24/7 email assistance via

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