Safe Harbor codes appearing as blank on BN990

We a employees that were part time and were not eligible for benefits. They moved into full time positions. Their Initial Measurement found not 'Not Eligible' and so did the Standard Measurement. But they were offered benefits as soon as they went full time. The months when they have benefits we were expecting them to have a Safe Harbor code of 2C but it is appearing as blank. Does anyone have this situation?

VID049_OEET_How to use Custom Validation.zip

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Legacy Contributor

Were you ever able to resolve this because we're having the same issue.

Thanks.

Legacy Contributor

Yes, there was a recent ruling by the IRS that those codes are not required in some cases, when the employee enrolled in the plan offered it is redundant since the enrollment appears below. I think there is a knowledgebase item regarding this.

d-wilcox

From what I understand, you're supposed to be able to override on the BN27.1, 27.2 etc... but it did not work for me. We actually have three patches that need to be put in so I am hoping it will work afterwards. Look at "How do I process ACA Reporting Entity Information" and ACA Employee Information.

d-wilcox

Thanks Sharon.

Legacy Contributor

Hi Sharon and Others,

Does anyone have any IRS official documentation that states line 16 should be left blank if line 14=1A? The 1095 instructions does not give any indication that line 16 should be blank if you have a 1A. And the 1095 instructions clearly state to assign a 2C for any month the employee was enrolled in health coverage.

All I can find is information that is targeted to software developers and it's dated July, 2015 and includes a disclaimer to the instructions to the forms should be referenced.

We're concerned that leaving it as 1A and Blank will lead to questions from employees since the instructions on the back clearly state they should be a 1C if they had coverage.

Legacy Contributor

Derek: Below is the link to IRS presentation - page 15, question 6. Hope this helps.
www.irs.gov/.../January 2016 AIR Webinar.pdf

Legacy Contributor

Thanks Mindy, we'll take a look at it.

Legacy Contributor

I wanted to close the loop on what we ended up doing.

We were reluctant to rely on a presentation without an official IRS notice or revised 1095-C instructions. We also talked to others who have already received their 1095C from their employers and they reported having a 1A/2C combination.

Infor support was able to help us get our safe harbor codes back. The fix required us to add a message in MSGMNT. I believe you need to have the latest BN990 patches for this to work.

If anyone else is interested in this solution, I recommend opening a ticket with Infor for more information.

Legacy Contributor

What message did you end up adding to the MSGMNT field?
We just installed the latest patch for the BN990 and some are safe harbor codes are still showing up blank.

Legacy Contributor

Add message 751 to MSGMNT for BN990 processing, so the safe harbor code will not be blanked out when the offer code is 1A. No need to compile after that msg is added. Contact support if needing additional assistance.

Legacy Contributor

If you go into the BN990 messages and you don't have message 750, I believe that means you aren't at the right patch level. Msg 750 has informational text describing the option of adding msg 751.

Details of message to add:

Category: BN990
Number: 751
Xlate: Y
Message: 1A

+Derek

Legacy Contributor

Thanks for the information. I think I got it now.

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