We received this from Suburban regarding their 1094C report and Line 22. Suburban there are two items checked and they are asking can it be updated to only show option C. (Below is the screen shot for Suburban and what comes up on their 1094C). In red below are the descriptions that were sent to me on 4/11 regarding the codes found in Line 22 of the 1094C form. I included the client email as you scroll down so you could see the conversation information.

Per the Client’s compliance attorney their feedback was different than the descriptions below. “you can only check box A OR B if you are using the Federal Poverty Level to determine affordability… and even if you are, it is not necessary to check either one as it only means that you have the ability to provide a condensed statement to employees rather than the 1095C. Every employer should check box C.”

I see in the description below, Box C is still being worked on, so not sure how to address this one. I am not sure what is correct. I checked the client’s population and they do have people with the 1A code for all months. Can you have your ACA experts weigh in on this one. Appreciate it.

Descriptions Provided by EBS

Line 22 Box A (Qualifying Offer Method) may be checked if at least one ACA-FT employee received a Qualifying Offer for all months the employee was ACA-FT during the year.

Line 22 Box B (Qualifying Offer Method Transition Relief) may be checked if the employer made a Qualifying Offer to at least 95% of its ACA-FT employees during at least one calendar month in the year.

Line 22 Box C : This is in development phase.

Line 22 Box D

Employer offered for all months of the calendar year, affordable coverage that provided minimum value to at least 98% of employees receiving Form 1095-C

MEC to dependents.