Completing Line 16 of ACA Form 1095-C

Posted by BAS - 19 January, 2017

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Applicable Large Employers (those with 50 or more full-time/full-time equivalent employees in the prior year) should be in the process of completing their Form 1095 Forms.  An ALE must furnish Form 1095-C to full-time employees and employees covered under a self-funded health plan.

Last week (see our article here) we discussed how to report offers of coverage on Line 14 of Form 1095-C.  This week we will address another of the more difficult parts of the form to complete:  Line 16 is used to identify specific situations applying to employees.  A brief summary of the Line 16 Codes follows. 

  • 2A.  Not employed during the month.  This Code indicates that the individual was not employed on any day during the month.
  • 2B.  Not a full-time employee.  This Code indicates that the employee was not a full-time employee for the month and did not enroll in coverage.  It also is used when an employee terminates employment during the month and the offer of coverage ended before the end of the month due to the termination.
  • 2C.  Employee enrolled in coverage for the month and coverage effective for the entire month.  This code can be used only if the employee was a full-time employee for at least one month during the year.
  • 2D.  Employee in limited non-assessment period.  This code is used if there is a period during which a penalty would not be assessed if coverage is not offered.  These periods include:  first three months of first calendar year as ALE member; waiting period under the monthly measurement method; waiting period under the look-back measurement method; initial measurement period and administrative period under look-back method; period following change in employment status under look-back measurement method; first calendar month of employment.
  • 2E.  Multiemployer plan interim relief.  This code is used to have an ALE member being treated as offering health coverage if the employer is required by a collective bargaining agreement to make contributions to a plan that does not offer minimum essential coverage.
  • 2F.  W-2 safe harbor.  This code may be used to show affordability based on W-2 earnings.
  • 2G.  Federal poverty line safe harbor. This code may be used to show affordability based on the federal poverty level.
  • 2H.  Rate of pay safe harbor. This code may be used to show affordability based on rate of pay.

There are ordering priorities for using each Code, and in some circumstances Line 16 may be left blank.


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