Information for Completing Form 1095-C Lines 14–16
Transcription
Information for Completing Form 1095-C Lines 14–16
Information for Completing Form 1095-C Lines 14–16* Scenario: Employee, Dependents and Spouse; Termination; Enrolls in COBRA; No Qualifying Offer The following example describes an employee scenario and indicates the proper entries for Lines 14–16 on Form 1095-C applicable to that scenario. Filers may find this information useful when completing Form 1095-C for an employee in a similar scenario. This example assumes that the employer offered the employee minimum essential coverage that provided minimum value, and offered the employee’s dependents and spouse minimum essential coverage. Please replace all data with your employee data. All 12 Months nd Example criteria Full-time employee is terminated on May 8 Employee was enrolled in coverage for employee, dependents and spouse; premium is $105.00 Employee enrolls in COBRA for employee, dependents and spouse for the remainder of the year Feb Mar Apr May June July Aug Sept Oct Nov Dec Line 14 1E 1E 1E 1E 1H 1H 1H 1H 1H 1H 1H 1H Line 15 $105.00 $105.00 $105.00 $105.00 Line 16 2C 2C 2C 2C 2A 2A 2A 2A la Jan 2A 2A 2A 2A G re at Explanation Code 1E is entered on Line 14 in January–April, since an offer of coverage was made to the employee, spouse and dependents in these months. Code 1H is entered in May–December, since no offer of coverage should be reported in any month in which the offer of COBRA applies due to employee termination. The premium amount of $105.00 is entered on Line 15 in January–April, representing the employee share of the lowest cost monthly premium for self-only minimum value coverage. Line 15 is left blank in May–December since no offer of coverage should be reported in any month in which the offer of COBRA applies due to employee termination. Do not enter the COBRA premium in these months. Code 2C is entered on Line 16 in January–April indicating that the employee enrolled in the coverage offered. Code 2A is entered in May–December indicating that the employee was not employed during these months. *Greatland Corporation does not provide tax, legal or accounting advice. This document has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors before engaging in any transaction. nd Frequently Asked Questions What is the difference between Code 1A and Code 1E on Line 14 of Form 1095-C? Code 1A Qualifying Offer is minimum essential coverage (MEC) providing minimum value offered to a full-time employee with the employee contribution for self-only coverage equal to or less than 9.5% of the mainland single federal poverty line and at least MEC offered to spouse and dependents. Code 1E is MEC providing minimum value offered to employee and at least MEC offered to dependents and spouse. Code 1A is a subset of Code 1E, but has to be offered at a low price to be designated as a Qualifying Offer. The employee contribution for self-only coverage must be less than 9.5% of the mainland single federal poverty line. If MEC providing minimum value is offered to the employee, and MEC is offered to the spouse and dependents with the employee contribution for self-only coverage at a higher price, then the offer is not a Qualifying Offer and the Applicable Large Employer (ALE) would enter Code 1E on Line 14. The ALE does not have to use Code 1A, but if the ALE uses Code 1E then the ALE must also report the amount of the required employee contribution for the self-only coverage on Line 15. How should an Applicable Large Employer (ALE) complete Line 14 of Form 1095-C for a full-time employee who terminates employment during a calendar year and receives an offer of COBRA continuation coverage? An offer of COBRA continuation coverage that is made to a former employee due to termination of employment is not reported as an offer of coverage on Line 14 of Form 1095-C. For a terminated employee, Code 1H (No offer of coverage) should be entered for any month in which the offer of COBRA coverage applies. How should an Applicable Large Employer (ALE) complete Lines 14–16 of Form 1095-C for an ongoing employee who receives an offer of COBRA continuation coverage due to a reduction in hours? An ALE making an offer of COBRA continuation coverage to an ongoing employee who loses eligibility for non-COBRA coverage due to a reduction in hours (for instance, a change from full-time to part-time status resulting in loss of eligibility under the plan) should report the offer of COBRA coverage as an offer of coverage on Lines 14–16 of Form 1095-C. G re at la *Greatland Corporation does not provide tax, legal or accounting advice. This document has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors before engaging in any transaction. Form 1095-C Lines 14–16 Codes* Line 14 – Offer of Coverage Line 14 specifies the type of coverage, if any, offered to an employee, spouse and dependents. The code must indicate the coverage the employee was offered; however, it may not match the coverage in which the employee is actually enrolled. For example, if an employee is offered family coverage but enrolls in employee-only coverage, Line 14 must indicate that the employee was offered family coverage. A code must be entered for each calendar month even if the employee was not a full-time employee for one or more months. Alternatively, the “All 12 Months” box may be completed if the same offer applies to all 12 months. nd Line 15 – Employee Share of Lowest Cost Monthly Premium for Self-Only Minimum Value Coverage Enter the amount of the employee share of the lowest cost monthly premium for self-only minimum essential coverage (MEC) providing minimum value (MV) offered to the employee. This amount may not equal the amount the employee is actually paying for coverage. For example, an employee enrolls in family coverage with a monthly premium of $200.00. The monthly premium for employee-only coverage is $100.00 which is the amount that should be entered on Line 15. G re at la Line 14 Code Descriptions Qualifying offer: Minimum Essential Coverage (MEC) providing Minimum Value (MV) offered to 1A ful- time employee, and at least MEC offered to spouse and dependents. Employee contribution for self-only coverage is $93.18 or less (for 2015). 1B MEC providing MV offered to employee only 1C MEC providing MV offered to employee and at least MEC offered to dependents (no spouse) 1D MEC providing MV offered to employee and at least MEC offered to spouse (no dependents) 1E MEC providing MV offered to employee and at least MEC offered to dependents and spouse. (If employee contribution for self-only coverage is more than $93.18 for 2015, use Code 1E.) 1F Offer of MEC NOT providing MV was made to employee, or employee and spouse or dependents, or employee, spouse and dependents 1G Offer of coverage to employee who was not a full- time employee for any month and who enrolled in self-insured coverage for one or more months 1H No offer of coverage to the employee, or the offer was not MEC Qualifying Offer Transition Relief for 2015: Employee (and spouse or dependents) received no 1I offer of coverage, received an offer that is not a qualifying offer, or received a qualifying offer for less than 12 months. Line 15 Entry Leave blank Required Required Required Required Leave blank Leave blank Leave blank Leave blank Line 16 – Applicable Section 4980H Safe Harbor Line 16 provides an opportunity for an employer to indicate an exception to a penalty. Completing this line is optional, however it is in the employer’s best interest to provide the information if it is applicable. 2A 2B 2C 2D 2E Employee not employed during the month Employee is not a full-time employee Employee enrolled in coverage offered Employee is in a limited non-assessment period Multiemployer interim rule relief 2F 2G 2H 2I Section 4980H affordability Form W-2 safe harbor Section 4980H affordability federal poverty line safe harbor Section 4980H affordability rate of pay safe harbor Non-calendar year transition relief If more than one code applies to Line 16, use the following guidelines: If 2E and any other Code series 2 applies, enter 2E If 2C and any other Code series 2 applies other than Code 2E, enter 2C If 2B and 2D apply, enter 2D *Greatland Corporation does not provide tax, legal or accounting advice. This document has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors before engaging in any transaction.