Hi all - the client is saying the use of 1A on their forms is incorrect. The client has a standard rate and then another rate if the employee qualifies for the wellness award. If they qualify, the cost is less than the $94.05 but if they do not, it is greater. The client also has a 7/1/16 plan year.
Two questions -
How do we fix the code so it only recognizes a 1E instead of a 1A?
How do we calculate the cost if the first six months of the year are different than the last six?
Below is from the Client's broker -
The IRS has specified that when calculating “affordability”, with the exception of wellness programs designed to prevent or reduce tobacco use, affordability must be determined assuming that employees fail to satisfy the wellness program requirements. This means that the wellness premiums that Town of Cary employees actually paid for health coverage as shown in Workterra cannot be used on Line 15 and cannot be used in calculation of the affordability. When using the non-wellness rates for Town of Cary, the employee premium is in excess of the FPL safe harbor. That is why Cary cannot use the FPL safe harbor. The ACA Team seems to have no understanding of Cary’s specifics and thus is making the error of using wellness rates in affordability calculation.
The IRS has specified that different safe harbors may be applied to the employee population only provided it is done on a uniform and consistent basis for all employees within a “reasonable category”. Reasonable categories generally include specified job categories, hourly or salaried employees, geographic location and other similar bona fide business criteria. The 1095-C forms that Workterra generated for Cary apply the FPL safe harbor based on only the wellness premium (which is the mistake addressed in item 1 above) and are applying the FPL safe harbor and the W-2 safe harbor to different employee populations based only on the amount of the premium paid and not on any “reasonable category” of bona fide business criteria.
In summary, the 1095-C forms are wrong for the reasons above and they are not acceptable to the Town of Cary or the IRS. The Town requires new 1095-C forms using the W-2 safe harbor codes and the line 15 dollar amounts specified in other emails to you. (For example, Line 14 Code 1A is changed to 1E and Cary’s employee only monthly premium contribution without any reward for wellness for Line 15 is $162.50 from January 2016 – June 2016 and $176.59 from July 2016 – December 2016.)
Hi Jennifer Leugers
Please verify ACA Customization on this company and please make changes on this screen if necessary,so that the report can be re-run with latest customization.
CC: Nandkumar Prabhakar Karlekar,Sachin Hingole