1095-C Line 16, Code 2C

[jsb]

Need a 1095-C Reporting wizard... -- Code 2C, employee enrolled in coverage. Code 1E, MEC offer to Ee+spouse+kids. Have bi-weekly enrollment and eligibility for our plans. Employee eligible for coverage on 6/29/15 but didn't enroll until 7/13.

Colleague suggests July reporting should be 1E/2C, because employee was offered coverage for whole month, even though no coverage effective until 7/13.

I think July reporting should be 1E/2H because employee's coverage was not effective for every day of the month. 2H definitely applies.

Would appreciate any thoughts, and especially a point to any IRS authority or specific example on this bit of minutia.

[J Simmons]

By 1E for Line 14 coding, I assume that the offer made does not meet the Qualifying Offer (1A). If 1A and 1E both apply, I'd suggest you use 1A rather than 1E.

As for Line 16 coding, 2C does not apply because the employee was not enrolled in health coveraged offered by the employer for each day of the month. See page 11 (IRS Instructions for Forms 1094-C and 1095-C (2015)) for the every-day-of-the-month requirement for 2C coding to apply.

If you are using the affordability rate of pay safe harbor for the price to employees at which self-only coverage is offered to them (along with coverage offers for spouse and/or dependents at other prices to the employee), then I agree that 2H would be the proper Line 16 coding.

[jsb]

Thanks for the speedy reply. Yes, 1A does not apply to this employee. My colleague had been reading the instructions and grouping words as indicated by the inserted parentheses:

"Employee enrolled in coverage offered. Enter code 2C for any month in which the employee enrolled in health coverage (offered by the employer for each day of the month), regardless...";

She has since changed her tune.

Almost all employees (except 10-20 out of 6,000) qualify 2H.