BN990 Removal of 2C Safe Harbor Code for 1A Offers

manisht

I can see in the latest BN990 Logic document that the 2C Safe Harbor Code was removed from populating when there is a 1A Offer code. This does not make sense to me at all. The IRS instructions do not explain this update or reflect this change that I can find, so can someone point me to instructions that do call out this change so that I could direct employees to see this?

When I first setup ACA almost our entire population had the codes of 1A and 2C on their forms...it looks very strange now that I have rerun them and the 2C Code no longer shows up. To me that we are not telling me that they enrolled in the plan any longer ...I am confused about this change from Infor and am searching for some clarification.

Legacy Contributor

Offer Code 1A was clarified in the January 2016 IRS AIR training – page 15.

On Form 1095-C if Code 1A is entered on Line 14, are entries required in either Line 15 or Line 16?

No entry is required in Line 15 or Line 16 when Code 1A is entered in Line 14. Therefore, if an employer made a Qualifying Offer for all 12 months of the calendar year it can enter Code 1A in the All 12 Months box in Line 14 and no other entries are needed in Lines 15 or 16. If an employer made a Qualifying offer for one or more months in the calendar year, but not all 12 months, it can enter Code 1A in the monthly boxes of Line 14 for months in which a Qualifying Offer was made. For any month in which Code 1A is entered, no entries are needed in the corresponding monthly boxes in Lines 15 or 16.