Reviewing ACA Form 1095- Line 16

Posted by BAS - 20 January, 2022

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The deadline for furnishing form 1095-C is fast approaching. Completing lines 14 and 16 on the form is the most daunting task for employers. Reviewing coding on these forms is especially important this year as the IRS has rescinded any good-faith compliance relief for erroneous completion of 2021 ACA forms.

Line 16 of the Form 1095-C is where the employer identifies that one of the following situations applied to the employee.

  • The employee was not employed or was not a full-time employee,
  • The employee enrolled in the minimum essential coverage offered,
  • The employee was in a Limited Non-Assessment Period
  • The ALE Member met one of the affordability safe harbors with respect to this employee, or
  • The ALE Member was eligible for multiemployer interim rule relief.

If no indicator code applies, line 16 blank is left blank. The available codes are as follows:

  • Employee not employed during the month.
  • Employee not a full-time employee.
  • Employee enrolled in health coverage offered.
  • Employee in a section 4980H(b) Limited Non-Assessment Period.
  • Multiemployer interim rule relief.
  • Section 4980H affordability Form W-2 safe harbor.
  • Section 4980H affordability federal poverty line safe harbor.
  • Section 4980H affordability rate of pay safe harbor.
  • Reserved for future use

Employers should review Line 16 of their forms for each employee before distribution.

Topics: Health Care Reform (ACA), Affordable Care Act, HR & Benefit Plans, HR & Benefits News


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