Affordable Care Act (ACA) Application Guide

Affordable Care Act (ACA) Application Guide







AFFORDABLE CARE ACT (ACA) APPLICATION GUIDE


1095-C Form: Where the Data Comes From


  • Part 1 (Employee and Employer data) – The only thing that needs to be entered in the ACA application is line 10 (contact phone).  See the Reporting section on page 18.  Note: The Contact Name also shown in the Reporting section is needed for the 1094-C form (not shown in this document).  
  • Part 2 Lines 14 and 16 – These come from the Employee Status\Employer Offer and Coverage screen (see pages 11 to 15).
  • Part 2 Line 15 - The default amount will be entered by your payroll service bureau. This can be overridden for each employee on the Affordability\Deduction Override screen (see pages 20 & 21).
  • Part 3 check box – If applicable, your payroll service provider will check the corresponding box in company setup for you.
  • Part 3 Covered Individuals - If applicable, this data will come from the Household Information tab (see pages 16 to 18).


Note: Part 2 Plan Start Month is not required to be filled in 2018.  2019 rules are not out yet.



Sample form From IRS.gov


Opening the Affordable Care Act Application


Select the AFFORDABLE CARE ACT application from the applications drop-down at the top-left of your screen.  You may wish to select a specific company to work with first.  



Note: The ACA application can be used while the company is set to read only (temporarily or permanently) or is in read-only while a payroll is in process.








Dashboard


The dashboard will reflect all companies with the ACA feature activated that the user has access to, unless a specific company is “Selected”.


  • Green checks indicate that particular section is set up correctly and/or in compliance.  A red X indicates that it isn’t.


  • The Review Offers item calculates the percentage of full time employees and their dependents that have been offered coverage in the current month.  If this is 95% or higher the dashboard will show a check.  Note: This is intended to be used throughout the year.  If you are using the app in the following year, this measure will not be useful.  For example, you are working on 2019 filing in January 2020.


  • The Review Employee Status item indicates whether or not the employees have the correct ACA Job Classifications assigned to them.  This will ignore the classifications which have been overridden by the user.


  • The Review Affordability item indicates that the full time employees can afford the insurance in the current month. Note: This is intended to be used throughout the year.  If you are using the app in the following year, this measure will not be useful.  For example, you are working on 2019 filing in January 2020.


  • The blue boxes can be clicked to access the corresponding areas of the ACA application and/or setup.












Large Employer Status




The Large Employer Status tab will show you all companies that you have permission to view that are set up for ACA (unless you have a specific one “selected”).  This shows data for the current year.  Check the header to verify the year.


  • The “Employee Count” column shows the number of employees that have hours worked in the current year (minus seasonal and contract employees).


  • The “Employer Status” column indicates whether the client is considered a small or large employer in the current year.  If the annual average of each month’s Total (FT + FTE) employees is 50 or more, it is considered a large employer.


  • Full Time employees (FT) are those that worked 130 or more hours in a month.  The Number of Full Time Equivalent Employees (FTEs) is calculated by totaling the number of hours worked in the month by all non-full time employees (the hours included per employee are capped at 120) and dividing by 120.  The hours in a pay run are all assigned to the month of its check date.  


  • 1094-C and 1095-C forms with 2019 insurance offer and coverage data are required if the company was considered a large employer in 2018.  Check with your payroll service provider if you have questions about your 2018 status.


  • In the case of common ownership (an ALE Group), the “Totals” (FT+FTE) for each company/member are combined and displayed in the “CMO Total” line.  If this totals 50 or more, the group and all of its companies, are considered large employers for 2019.  Note: The Company Code listed in the header is that of the “parent” company (see next page for common ownership setup).





Common Ownership


To set up Common Ownership Companies (members of an ALE group) make sure to “Clear” the company list so all your companies are shown in the ACA app.


Click the Common Ownership link on the Large Employer Status tab.





You will need to pick a “parent” or “main” company for the group.  Click on the Edit Details button beside this company.





Click in the Child Companies box and select the other members of the ALE Group (one at a time).  Click the SAVE button when finished.





Employee Status 


This tab lets you see the status of each employee and whether they are in compliance according to their assigned ACA Job Classification.  It will also indicate which employees will receive 1095-C forms.  This information can be edited or overwritten.





ACA Job Classification 

Full time status is based on 130 hours per month.  If an employee works 130 or more hours in any month, he/she is considered full time. The hours in a pay run are all assigned to the month of its check date.  (Note: This classification can manually be overridden if needed.  For example, if the employer is calculating hours worked by pay period instead of by pay check.  This will be covered later in this document.)


Employees that are not in compliance will be shown in red and the “ACA Classification Error Flag” will be checked.  An employee could be out of compliance for one of two reasons: 

  • The employee’s ACA Job Classification is set to full time and he/she did not work 130 or more hours in any month.
  • The employee is set to part time and worked 130 or more hours in one or more months.


Click the “Import ACA Job Class” button to update the ACA Job Classification in the ACA App with the Job Classification from CyberPay/CyberPay Online. When companies are first added to the ACA app, the ACA Job Class is copied from this field.  It is not kept in sync after that.




You can filter the view using the “ACA Job Classification Filter” at the top.





Receiving 1095-C 

This column will indicate which employees will receive 1095-C forms.  Employees that have worked 130 or more hours in any month in 2019 will get a 1095-C unless they are seasonal or contract. (Note: This flag can also be manually overridden if needed.  For example, if the employer is calculating hours worked by pay period instead of by pay check.  This will be covered later in this document.)




The Employee Status data can be exported to a .csv file to review for accuracy or archival by clicking either of the “Export to CSV” buttons.  Files with .csv extensions can be opened with Microsoft Excel and/or saved as Excel (.xls or .xlsx) files.  Use the down arrow beside the column headers to change the sort order and/or to filter the records.





Employee Overrides (one employee at a time)


The “Receiving 1095-C”, “ACA Job Classification”, and “ACA Classification Error Flag” (and red highlight) can be overridden. Overrides can be set for one employee at a time or for multiple employees together.  Click the Overrides button for an employee on this screen to override just that employee.  Click the “Overrides” link at the top of the screen to work with multiple employees at the same time. This will be covered later in this document.




This window will open.  




  • Do not warn if Full Time Classification is incorrect: Check this box if the employee is set to Full Time, but the application is calculating them as Part Time.  This will prevent the red highlight and the error check mark.  Note:  If in the future, the employee gets enough hours in a month to be considered full time by the application, you will not need to change this setting.


  • Do not warn if Non-Full Time Classification is incorrect: If the application is calculating that an employee should be full time, but you want to classify them as part time, contract, or seasonal, check this box to stop the warning.


  • Reason Do Not Warn was used: It is a good idea to make a note of why you used one of the above overrides.  You might also want to keep documentation proving that the application needed to be overridden in case of an audit.


  • Force Receive 1095-C: Check this box to make sure that the employee receives a 1095-C form regardless of the monthly hours shown on the Employee Status tab.


  • Do Not Receive 1095-C: Check this box to make sure that the employee does NOT receive a 1095-C form regardless of the monthly hours shown on the Employee Status tab.


  • Reason Override 1095-C was used: It is a good idea to make a note of why you set one of the above overrides.  You might also want to keep documentation proving that the application needed to be overridden in case of an audit.


  • ACA Job Classification:  You may manually change the ACA Job Classification with either of the overrides options on this tab or on the Employee Offer and Coverage tab.


  • Click the Save ACA Options button when finished.


Note: While an override is effective, you will see asterisks in the Receiving 1095-C and/or ACA Classification Error Flag columns for the employee.  

Example:  An employee is expected to be full time at hire.  So, the ACA Job Classification is overridden to that status.  The application considers him/her to be part time because he/she does not have 130 or more hours in any one month.  These columns will show the asterisks until/unless the employee later gets enough hours to be considered full time.  When/if this occurs, you do not have to reverse your override setting.  The application will stop showing the asterisks because the override isn’t actually effective any longer, because both the override and the application agree.




The override values are included in the .CSV export:

  • Override Calculated 1095-C (column AA) – When this column shows “Override”, it indicates that either the “Force Receive 1095-C” or “Do Not Receive 1095-C” option is checked AND that it actually overrides or changes what would happen if not checked.
  • Error Override Status (column AB) – This will say “Effective” or “Ineffective” if one of the warn options is selected and “No Override” if neither are selected.  “Effective” means that the Full Time or Part Time status that is set for the employee is not what the system calculates AND the warning option selected turns off the red warning.  “Ineffective” means that the Full Time or Part Time that is set is the same as what the system is calculating so the selected override option isn’t doing anything.


Multiple Employee Overrides


Click on the “Overrides” link from the Employee Status tab to set overrides for multiple employees at the same time.



Then click the “Edit Details” button for the desired company.



Use the “ACA Job Classification” and/or the “Receiving 1095-C” filters to narrow the results.  Then select one or more employees by clicking the box next to their names.  Next, click the “Overrides” button.  





Fill in the desired override data for the selected employees and click the “Save ACA Options” button.  See the description of these fields in the prior section.




Click the “Save ACA Options” button to apply these settings to all selected employees.



Average Hours Report


Click the “Average Hours Report” link on the Employee Status tab to estimate the hours each employee worked by pay period instead of by check date.  





Select the companies that you want to include in the report (export).  Click the “Select All” link at the top to include all companies shown.  Then, click the “Export to CSV” button.



This will export a file per selected company in a zipped folder.  This file estimates the hours worked per month using the payroll pay periods instead of the check dates.  If the pay period falls entirely in the one month, then all hours the employee worked are assigned to that month.  If the pay period spans more than one month, then the employee’s hours are averaged per day and then applied to the correct month.  This is an estimate, and may not correctly reflect the actual hours worked in the pay period’s months. 


Column H will show the current ACA Job Classification from the ACA app.  Column I will show what the ACA Job Calculation would be based on the hours in the file.  Column J will show “True” when columns H and I are not the same, thus indicating that a change/override may be necessary.






Employee Offer and Coverage


Click this link on the Employee Status tab to edit the ACA Job Classification and/or to set up the employees’ offers and harbors for the form 1095-C Part 2.




Next, click the “Edit Details” button next to the company that you want to work with.  






This screen is tab enabled which allows you to move from field to field by pressing your keyboard’s Tab key.


Use the “ACA Job Classification” filter to narrow the results.  Only Full Time employees receive 1095-C forms.  So, as long as you have the employees correctly classified, you only need to set offer and coverage codes for Full Time employees.


The “ACA Sync” button creates any missing employee 2019 Offer and Coverage records.  It will not delete or change existing records.  For example, a full time employee was recently hired, but isn’t showing on this page.  Click this button to add them.


Click to “Copy Prior” button to copy the Employee Offer and Coverage records from the previous year.  This will override existing records.


The ACA Job Classification column is originally populated from the “Job Classification” field from CPO’s Employee Setup.  However, after the employees are loaded into the ACA app, these fields are no longer linked.  



You should review the classification and choose the correct one for each employee.  Since this field is not synced with CPO, a change here will only affect the ACA app.


  • Full Time – EE worked 130 or more hours in one month
  • Part Time – EE did not work 130 hours in any month
  • Contract – Not getting 1095-C regardless of any hours recorded.  Be sure that you understand the Fed’s definition of contract before selecting it.
  • Seasonal – Employed less than six months and will not get 1095-C form regardless of hours worked.  Be sure that you understand the Fed’s definition of seasonal before selecting it.
  • The other choices should not be used in the ACA app at this time.


Next, you will choose the appropriate OFFER and HARBOR indicators for each employee.

  • If this was the same for an employee for all 12 months, only fill in the “12 Months Offer” and “12 Months Harbor”.
  • Otherwise fill in both of these (offer and harbor) for each of the twelve months Jan-Dec.  
  • To leave line 16 blank for an employee's 1095-C form, select the "XX No code applies, line 16 will be blank" option for the applicable harbor field(s).


Don’t forget to click the Save button often.


Actual IRS codes and an explanation of when each is used, is provided at the end of this document courtesy of Mammoth HR.


Note:  A suggested way to enter the monthly data is to click the “Select None” button and then check the month(s) that you want to work with and/or will fit on your screen.





Work with Multiple Employees


You can also work with multiple employees.  First select multiple employees by clicking the box to the left of their names.  Then click the “Work with Selected Employees” button. The following screen will pop up. Enter the desired offer and harbor for either ALL 12 Months or for individual months.  Then click the “Save for Selected” button.  Note: This method could be used for a single employee as well.




Before going to the Reporting tab to create 1095-C and 1094-C forms, click the “Check Coverage” button.  This will check that all Full Time employees have offer and coverage set up.

The Employee Offer and Coverage data can be exported to a .csv file to review for accuracy or archival by clicking the “Export to CSV” button.  Files with .csv extensions can be opened with Microsoft Excel and/or saved as Excel (.xls or .xlsx) files.  

Use the down arrow beside the column headers to change the sort order and/or to filter the records.



Calculate Codes Tool


For help entering the Offer and Harbor codes for the employees, click the “Calculate Codes” button.






Enter the codes to be used in each situation and press Calculate.  This tool is intended to get you started but you should verify the accuracy of the recommended codes.  





Importing Employee Offer and Coverage data


The ACA Job Classification and the Offer and Harbor codes can also be imported from a .csv file.  Click on the Import link to get started.




You can either download the template from this screen and fill it in from scratch, or export the current Offer and Coverage data to .csv, edit it, and then import it.  Remove the descriptions from the codes if doing the latter.  Only the number and letter are needed in the import file (i.e. 1A).  Be sure to save the file as .csv before importing it.  Note: Hire/rehire/termination dates have been added to this export to help users assign offer and harbor codes.


If any offer and/or harbor codes are left blank, and corresponding codes have previously been entered for the employee(s), they will be deleted.










Household Information (Self-insured clients only) 


This tab tracks dependents and their benefit elections, and flows through to the 1095-C Part III.  This tab is not visible unless the company is set to self-insured.  Check with your payroll service provider if your company has a self-insured policy but you cannot access this tab.


This tab only needs to be completed if the employer is self-insured.


Note: There is now an import available for dependents on the Coverage screen.

Click the New Dependent button to add one here.  

  • These can also be added by the employees from the ESS screen.






When the company is active in the ACA application and is self-insured, the dependents and coverage entered on the Dependents tab in the Employee Self Service (ESS) portal will flow to the Household Information tab in the ACA Application.  Note: Your payroll service provider can hide the Dependents tab for you if you do not want the employees to enter these.






Note: If the dependent’s Social Security Number is unknown and you wish this box to be empty for him/her on the form, enter 000-00-0000.


The Household Information data can be exported to a .csv file to review for accuracy or archival by clicking the “Export to CSV” button.  Files with .csv extensions can be opened with Microsoft Excel and/or saved as Excel (.xls or .xlsx) files.  Use the down arrow beside the column headers to change the sort order and/or to filter the records. 



Coverage (Self-Insured Clients Only)


Click on the Coverage link to add/edit data required for the 1095-C part 3. Also not required unless the employer is self-insured.




Check the months in which the dependents had coverage.




  • If you check the All Covered option for a dependent, the system will check all the months for that dependent.


  • The Copy Prior Year button will copy the dependents and their coverage from the prior year. This will replace coverage entered for the current year.  Note: Dependents for employees that did not receive pay in the current year will not be copied.


  • If you check the All button at the top of the screen, the system will check all months for all dependents.


  • The None button at the top of the screen will uncheck all months for all dependents.


  • The Copy button can be used to copy the elections for all dependents from one month to the next. For example selecting the Jan-Feb option will copy all the checks in the January boxes into the February boxes for all dependents.  


  • The Calculate Coverage button will check the appropriate months if both the "Coverage Begin Date" and "Coverage End Date" are filled in for the current year.


Click the Cancel button to exit without saving.


Don’t forget to click the Save button to keep your changes.


The Dependent Coverage data can be exported to a .csv file to review for accuracy or archival by clicking the “Export to CSV” button.  Files with .csv extensions can be opened with Microsoft Excel and/or saved as Excel (.xls or .xlsx) files.  Use the down arrow beside the column headers to change the sort order and/or to filter the records. 

Importing Dependents and Coverage


Users can now import dependents and their coverage.  This process will delete any dependents in the App for the year and replace them with those in the file.  Go to the Coverage tab and Export the current data to CSV.  Then edit the content of the file. Dependents can be added or removed and the coverage set correctly for the current ACA year.  When ready, click on the Import link also on the Coverage tab.




Reporting (1095-C and 1094-C)

This tab provides samples of the 1095-C and 1094-C forms. These are for reference only.  




Transmit 1094-C/1095-C



Click the “Transmit 1094-C/1095-C” link on the Reporting tab to approve and submit the ACA data to your payroll service provider if/when requested.  Your provider may not require you to do this.


  • Before submitting the data, verify that all data for the 1095-C form is correct.  See the “1095-C Review” section of this document to review what data is included on that form and where in this application it is entered.  


  • Additionally, make certain that all employees who should be receiving a 1095-C form have a checkmark in the “Receiving 1095-C” column on the Employee Status page.  These are the employees that will receive 1095-C forms.  


  • Check that the company contact information and phone number are filled in. This information will be used on the 1094-C and 1095-C forms.  This must be done for all of your companies before the data can be submitted.  Click the “Inline Edit” button to enter/edit and save this information.  





When you are ready to submit the data:


  1. Select the company(ies) for which you wish to submit ACA data.  Then click the Submit button.




  1. Read the agreement and click the Agree Button.  




This completes the submission.  Your payroll service provider will process the 1095-C and 1094-C forms for you.



Affordability


This tab shows the affordability of the insurance per employee per month.  


  • The ACA application uses the Form W-2 Safe Harbor method to calculate affordability.  Note: There are other methods that employers can use to calculate affordability outside of the application.  


  • The Form W-2 Safe Harbor method is evaluated at the end of calendar or plan year.  The insurance is considered affordable if the employee portion of the self-only premium does not exceed 9.86% (2019 plans) of the employee’s W-2 Box 1 (FIT) wages.  


  • This tab will show you the monthly (either current or past) FIT taxable wage of the employees.  The wage multiplied by 9.69% is shown and compared to the “Employee Deduction Paid”.  If the “Difference” is less than 0, the coverage is considered unaffordable and the employee is shown in red.  


  • The Form W-2 Safe Harbor method is an annual calculation, so there is a little leeway on monthly calculations.






There are 2 different views available.  The “ACA Affordability View (Current Month)” and “ACA Affordability View (Past Month)”.  These views will change the wage field to be the total of the FIT taxable wages in the past month or the current month based on the current date.  


Use the “ACA Job Classification Filter” to narrow down the results shown.  For example, you might wish to only view (work with) Full Time employees.



The “Employee Deduction Paid” amount will come from the default employee share values entered for the company by the payroll provider unless overridden (see Deduction Override section below).


The Affordability data can be exported to a .csv file to review for accuracy or archival by clicking the “Export to CSV” button.  Files with .csv extensions can be opened with Microsoft Excel and/or saved as Excel (.xls or .xlsx) file. Use the down arrow beside the column headers to change the sort order and/or to filter the records.



Annual Affordability Report


Since the Form W-2 Safe Harbor method is an annual calculation, it is good to review the entire year.  Employers may wish to archive these reports.  Note: This report is based on the calendar year.







Deduction Override (Employee override of the Employee Share of Lowest Cost Monthly Premium)


Click on the “Deduction Override” link to override the Employee Share of Lowest Cost Monthly Premium, for Self-Only Minimum Value Coverage.  This will override the company default value entered by your provider for Part 2, line 15 of the 1095-C form.  This will also affect the Affordability tab in the ACA app.  





Then, click the Edit Details button for the client for which you wish to enter employee override values.





This screen is tab enabled which allows you to move from field to field by pressing your keyboard’s Tab key.


If the employee’s share was the same for all 12 months, you only need to enter the amount into the “12 Months Override”.  Otherwise, enter the correct amount for each month.


Don’t forget, click SAVE often.


Use the “ACA Job Classification Filter” to narrow down the results shown.  For example, you might wish to only view (work with) Full Time employees.





It is suggested that you click the “Select None” button and then select the months that you wish to work with and/or will fit on your screen. 


The Deduction Override data can be exported to a .csv file to review for accuracy or archival by clicking the “Export to CSV” button.  Files with .csv extensions can be opened with Microsoft Excel and/or saved as Excel (.xls or .xlsx) files.  Use the down arrow beside the column headers to change the sort order and/or to filter the records. 


Import Deduction Override Amounts (Override the EE Share of Lowest Cost Monthly Premium)


Click on the Import link on the Affordability tab to import employee deduction override amounts.





Download the template file, enter the data, and save it as a .csv file.  Then, fill out the form and click the “Import” button.  Notice: If any columns for number values are left blank in the file being imported, and corresponding columns have previously been entered for the employee(s), they will be deleted from the ACA app.




Export Data


There are several places in the ACA app from which you can export data.  You may wish to export data to archive it on your computer/network or just to review it for accuracy.  The following have CSV exports: Employee Status tab; Employee Offer and Coverage Screen; Household Information tab; Coverage screen; Affordability tab; and Deduction Override.  Note: .csv files can be opened with Microsoft Excel and/or saved as Excel files.





Sorting and Filtering Data

When you see these icons,  or  , in the column headers of a screen, you can click on them to sort by that column and/or enter specific criteria to filter the records. 


   








Importing and Bulk Updating Data


The following data can be imported into the ACA Application: 

  • ACA Job Classification and Employee Offer and Coverage Data.  See page 15.
  • Deduction Override Amounts.  See page 21.
  • Dependents for Self-Insured Employers. See page 18.


The following can be bulk updated in the ACA Application:

  • ACA Job Classification (description & warning) Overrides.  See page 10.
  • Receiving 1095-C Form Flag Overrides.  See page 10.
  • ACA Job Classification and Employee Offer and Coverage.  See bottom of page 13.



Viewing 1095-C forms in the Employee Self Service (ESS) portal

Your payroll service provider may provide the 1095-C form through the ESS portal.  This is optional and may be in addition to, or instead of, a paper copy.




SECTION 6056 REPORTING CODE DESCRIPTIONS FOR THE 1095-C

Part II, Line 14 - (What medical benefit did you offer the employee?)


Code

Description

1A

A plan meeting the “minimum value” requirements was offered to this full-time employee with employee contribution for self-only coverage equal to or less $99.75/month (in 2019) and at least minimum essential coverage was offered to this employee’s spouse and dependent children. You will use this code if using the Federal Poverty Level Affordability Safe Harbor for this particular employee in addition to the above requirements. This is also known as the “qualifying offer”.

1B

A plan meeting the “minimum value” requirements was offered to this full-time employee only, but not to this employee’s spouse or dependent children. It’s rare, but some companies do not allow any dependents to enroll on the plan. This would be the code companies that do not allow dependents to enroll in the plan would use. 

1C

A plan meeting the “minimum value” requirements was offered to this full-time employee and at least minimum essential coverage was offered to this employee’s dependent children, but not to this employee’s spouse. This code would be used for most spousal carve-out plans if coverage is not offered to the employee’s spouse. 

1D

A plan meeting the “minimum value” requirements was offered to this full-time employee and at least minimum essential coverage was offered to this employee’s spouse, but not to this employee’s dependent children. This one would be very, very rare. 

1E

A plan meeting the “minimum value” requirements was offered to this full-time employee and at least minimum essential coverage was offered to both this employee’s dependent children and spouse. This will be the most frequently used code. So if the company is not planning to use the Federal Poverty Level Safe Harbor and offered coverage to this full-time employee and his/her family members, this would be the correct code. 

1F

Minimum essential coverage NOT providing minimum value offered to employee, employee and spouse and/or employee, spouse and dependent children. This could be a “skinny” or “mini” health plan that meets the threshold for minimum essential coverage, but not for minimum value. 

1G

An offer of coverage was made to this employee who was not a full-time employee for any month of the calendar year and who enrolled in self-insured coverage for one or more months of the calendar year. You would only use this code if the company sponsors a self-funded plan and allows a part-time or non-employee to enroll, so this one is rare. This code should always be placed in the “all 12 months” box if selected. 

1H

This employee received no offer of health coverage. Or, this employee received an offer of health coverage that fails to meet minimum essential coverage requirements. This code is used for any month that the employee did not work for you or when the employee was in their waiting period. 

1I

Not applicable in 2019.

1J

A plan meeting the “minimum value” requirements was offered to this full-time employee and at least minimum essential coverage was conditionally offered to this employee’s spouse, but not to this employee’s dependent children.

1K

A plan meeting the “minimum value” requirements was offered to this full-time employee; at least minimum essential coverage was offered to this employee’s dependent children; and at least minimum essential coverage was conditionally offered to this employee’s spouse.


  Legal Disclaimer: This document is intended for informational purposes only, and does not constitute legal information or advice. This
information and all HR Support Center materials are provided in consultation with federal and state statutes and do not encompass other
regulations that may exist, such as local ordinances. Transmission of documents or information through the HR Support Center does not create an
attorney-client relationship. If you are seeking legal advice, you are encouraged to consult an attorney. |





* The most common codes are bolded and underlined. 

Part II, Line 16

(What did the employee do when you made the offer OR

What excuse do you have for failing to make the offer?)


Code

Description

2A

This employee was not employed on any day of the calendar month. Do not use this code if the employee was employed on any day in the month. For example, if the employee only worked a partial month because this was the month in which he/she was hired or terminated, do not use this code. This code will most commonly be used for new hires and employees who have terminated during the calendar year.

2B

The employee is not a full-time employee for the month and did not enroll in minimum essential coverage, if offered for the month. This is also the code to use if an employee terminates in the middle of the month and coverage is not extended through the end of the month. Also, use this code for January 2019 if the employee was offered health coverage no later than the first day of the first payroll period that begins in January 2019 and the coverage offered was affordable and provided minimum value. This does not apply to employees who are in their waiting period or measurement period.

2C

This employee was enrolled in the employer’s plan every day of this calendar month. Whether the spouse or dependents are enrolled has no effect on this code. This code will be the most common and if this code applies to the employee, it should supersede any other code that may also apply for this line.   

2D

Enter code 2D for any month during which an employee is in a Limited Non-Assessment Period, such as a waiting period or measurement period. 

2E

Enter code 2E for any month for which the multiemployer interim guidance applies for that employee. 

2F

The employer used the W-2 Affordability Safe Harbor for this employee for the year. If an employer uses this safe harbor for an employee, it must be used for all months of the calendar year for which the employee is offered health coverage.

2G

The employer used the Federal Poverty Level Affordability Safe Harbor for this employee for any month(s).

2H

The employer used the Rate of Pay Affordability Safe Harbor for this employee for any month(s).

2I

Not applicable in 2019.


  Legal Disclaimer: This document is intended for informational purposes only, and does not constitute legal information or advice.
This information and all HR Support Center materials are provided in consultation with federal and state statutes and do not
encompass other regulations that may exist, such as local ordinances. Transmission of documents or information through the HR
Support Center does not create an attorney-client relationship. If you are seeking legal advice, you are encouraged to consult an
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* The most common codes are bolded and underlined. 


Note: If the employee waives coverage, you could enter code 2F, 2G, or 2H depending on the method used to calculate the affordability. The ACA app uses the method covered in 2F, so you should use this unless the employer calculated affordability using another method.