Hi all - could you please review the below and see if we are able to do this on their form? If we aren't, could you please provide guidance as to why (i.e. why they don't satisfy as she is stating)?

Because SBM offered at least 70% of full-time employees some kind of minimum essential coverage (which includes a skinny MEC – regardless of affordability, regardless of minimum value) in all months of 2015, then we need to check the “YES” box in Line 23, column (a) of the 2015 Form 1094-C, letting the IRS know that SBM should not be subject to a 4980H(a) penalty for any month in 2015.

Also, I noticed that “Box C: Section 4980H Transition Relief” was not checked, but SBM would like it checked. This box can be checked if an employer had 100+ FT/FTEs in 2014. There is no other criteria for a large employer to meet, and it just means that if worst came to worst, and an employer owed a “sledgehammer”/4980H(a) penalty for 2015, the employer is eligible for the 80-person exclusion (instead of the normal 30-person exclusion) when calculating the penalty for 2015. There doesn’t seem to be any downside to checking this box if it applies. NOTE: If Line 22, Box C is checked in this situation, then also “B” needs to be entered under Part III (e) of Form 1095-C to indicate 100+ FT/FTEs.

Please make these adjustments and provide a new 1095-C so that I can get the CFO to sign off.