ACA Reporting Form 1095-C - W-2 Safe Harbor for Non-Calendar Year Plan?

[kmhaab]

The instructions for completing Form 1095-C state that an employer can only use the W-2 Affordability Safe Harbor if it applies for the entire year. I assume this means calendar year (tax year) as that is the reporting period. 

Are the rules any different for a non-calendar year health plan? For example, if the plan year is July 1 - June 30 and premiums are "affordable" Jan - June but increase on July 1 and are not affordable Jul - Dec, can the employer use the W-2 Safe Harbor code for only Jan - Jun? My interpretation is no, it seems straight forward, but I am getting push back from an accounting firm and would like to make sure I have not missed something. 

Thanks in advance.

[Brian Gilmore]

@Ryan Moulder has a really good post on this topic here: https://accord-aca.com/articles/amended-needed-for-form-w-2-affordability-safe-harbor