ACA REPORTING: IRS CODES
There are two series of IRS CODES for ACA reporting & compliance.
They relate to LINES 14 & 16 of FORM 1095-C, the individual employee form that ALEs, as health plan sponsors, must complete and distribute to all eligible employees.
See here for the difference between FORM 1095-B & 1095-C.
SERIES 1 CODES: LINE 14
SERIES 1 codes are used to populate LINE 14 of FORM 1095-C.
They code the employer’s Offer of Coverage to the individual employee.
- Was an individual offered coverage?
- What type of coverage were they offered?
- Plus what months was the coverage offered or not offered?
FORM 1095-C requires a value for each month, which can be represented by checking
either the 'ALL 12 MONTHS' box or by entering a value for each individual month.
SERIES 2 CODES: LINE 16
SERIES 2 codes are used to populate LINE 16 of Form 1095-C. They code:
- Whether the individual was employed and, if so, whether they were full or part time.
- Whether the employee was enrolled in coverage.
- Whether the employer is eligible for transition relief as an employer with a noncalendar year plan or as a contributor to a union health plan.
- Whether coverage was affordable and, if so, based on which SAFE HARBOR code.
- NOTE: LINE 15 of FORM 1095-C relates to offer AFFORDABILITY, recording where required the lowest-cost, self-only coverage offered the employee each month. Certain OFFER CODES require LINE 15 to remain blank.
- E.g. for OFFER CODE 1A or 1G, LINE 15 should NOT be populated.
- NOTE: REFERENCES TO AFFORDABILITY relate to employee-only coverage level.
- NOTE: AN OFFER OF COVERAGE is one that provides coverage for every day of a calendar month. There is an exception for terminated employees who would have been covered for the entire month, if not for the termination.
- NOTE: A CONDITIONAL OFFER OF COVERAGE to an employee’s spouse is an offer under which the employee and/or spouse must meet or not meet one or more criteria.
- E.g. the employee’s spouse may enroll only if the spouse is not eligible for coverage in his/her own employer-sponsored plan.
If you have questions regarding IRS CODING or any other aspect of ACA reporting & compliance, please contact BENEFITSCAPE, the leading ACA specialist.
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