ACA Reporting Case Scenarios: How Employer Waiting Periods Impact the 1095-C 

If you have started down the worm-hole of completing your annual 1095-C statements, you’ve probably hit some confusion upon reaching Part II. With 9 coded options to plugin for each month of line 14 (1A-1I) and eight coded options for line 16 (2A-2H), things can start to get tricky.

The standard majority of cases are not the problems. Rather, it’s the odd-ball scenarios that generate the biggest stalls in 1095-C production, causing most to flee to google or expensive legal counsel for guidance on their specific scenario.

At Benetech, we will be publishing a series of 1095-C case scenarios over the coming months as we enter into the first round of annual reporting. At the end of the blog will be the option to submit your specific 1095-C case that is causing you the most heartburn, and we’ll work on answering as much as we can in the coming months. The more you submit, the more we will research and write.

Scenario 1: Mary was hired by ABC Company on January 15, 2015 with the expectation of being full-time. Mary’s company has a standard 90-day waiting period for new enrollments. Mary accepts ABC Company’s coverage offer, which extends qualifying coverage to her spouse and dependents. ABC Company has a plan-renewal date of January 1.

How does Mary’s 1095-C Part II look when complete?

Note: the $$ in line 15 would be the employee monthly contribution amount for the lowest cost single-coverage minimum value plan.

Why: Mary’s waiting period did not end until April 15, so her coverage did not initiate until mid-April. ABC Company will not change from 1H (No offer of coverage) to 1E (Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to dependent(s) and spouse) until the offer extends for an entire calendar month.

ABC Company completes line 16 with 2D for January-April because Mary was in a Limited Non-Assessment Period (LNAP) for at least one day during those months. She would not be recorded as 2C (being enrolled in coverage offered) and having concluded her LNAP until the first day of the calendar month following the conclusion of her LNAP.

If it was a self-insured plan, Mary’s Part III would look as follows:

Notice the coverage for Mary and her family begins in April. For Part III (or the 1095-B for fully-insured plans) ABC Company will mark the box for each month that Mary and her family were enrolled in coverage for at least one day. Because Mary’s coverage began at the end of her LNAP on April 15, and she accepted the company’s offer of coverage, she and her family are noted as being enrolled in coverage during the month of April.

This blog is not intended to be legal advice nor should any discussion or opinion be construed as legal advice. Readers should contact legal counsel for legal advice.