Q.- One of our health plans has a $0 premium for an employee to purchase single-only coverage. We also offer a buy-up for spouse and dependent coverage. Since $0 is clearly affordable, should we still identify an ACA affordability safe harbor?
A.- Yes, you will likely want to identify the Federal Poverty Line safe harbor. Since your premium is $0, you are clearly under the threshold for the Federal Poverty Line. Using this safe harbor allows your plan to use Code A on Line 14 of Form 1095-C for your employees who are offered coverage and tells the IRS that your organization offered minimum essential coverage providing minimum value with an employee required contribution less than 9.5% of the mainland single federal poverty line.