TANGO HEALTH BLOG
By - March 6, 2015

Mastering 1095-C Forms – Questions From the Webinar

Our webinar on February 26th, 2015 generated more questions than we could answer in our short time slot, so we’ll be featuring the questions and their answers over a few blog posts. This post will focus on the three scenarios we covered – outlined below – with the questions that applied.

Mason was an ACA Full-time (FT) employee (40 hours per week) enrolled in coverage (spouse & dependents) whose hours are reduced to part-time (PT) (25 hours per week) on June 1st.

1095-C

Considering Mason’s situation, you might think his form would reflect his transition to part time.

Q: ­What if Mason was not a variable hour employee, but a FT employee working 40 hours/week, so he was not measured during a measurement period. He was added within 90 days of hire. Wouldn’t he lose coverage when his hours drop below 30?­

A: All new hires (including FT employees working >30 hours) need to be measured in a new hire measurement period to ensure that, regardless of the hours they’re hired to work, their actual hours worked during the initial measurement period are considered in determining their eligibility during the subsequent stability period. So in the case of a FT employee who drops to a position working less than 30 hours, while you could drop their coverage at the time of the status change, you would continue to measure them for the remainder of their measurement period. Then if at the end of the measurement period they have averaged 30 or more hours per week (including their FT and PT hours), you would be required to extend a new offer of coverage if they’ve previously been dropped, or extend their coverage throughout the entire stability period if they have not already been dropped.

1095-C

The correct version of the form for Mason’s situation.

Carol was an ACA Full-time employee (40 hours per week) enrolled in coverage (employee only), terminated on May 25th. She was rehired on Aug 3rd.

1095-C

This version inaccurately reflects Carol’s scenario.

Q: ­For Carol’s situation, what if coverage begins the first of the month following rehire?­

A: In this example, if Carol is rehired on August 3rd and coverage begins on September first, this would be compliant. You would report code 2C for January-May, code 2A for July and July, code 2D for August, and code 2C for September – December.

1095-C

The correct version of the scenario for Carol.

Q: In the example of Carol – wouldn’t she have to be offered  coverage again in September? I thought if breaks were less than 13 weeks, they had to be offered coverage by the first of the month after rehire date.­

A: This example was demonstrating a potential error in reporting for an employee in this situation by showing an employer erroneously counting September as an assessment period. In the case of Carol, the employer would need to offer coverage by the first of September.

Q: ­If there is a break in service of less than 13 weeks, must the company offer benefits immediately? Or by the 1st of following month?­ 

A: If there is a break in service of less than 13 weeks, the employer must offer benefits by the first of the following month.­

Q: ­With rehires, is it ok to defer reinstatement to first of the following month? 

A: For ACA purposes, the latest eligible rehires can be offered benefits is the first of the month following their rehire date.

Q: ­So if the break in employment if less than 13 weeks, any wait period that would normally be required of a new hire would be waived? They would start the first of the following month?­

A: Correct, an eligible employee with an employment break of less than 13 weeks would need to be offered benefits effective the first of the month following rehire.

Q: ­Can you share more about Full Time to Part Time Class changes, in terms of eligibility, including hours tracking processes when an employee goes to PT?­

A: All employees (including FT employees working >30 hours) need to have their hours tracked to ensure that, regardless of the hours they’re hired to work, their actual hours worked are considered in determining their eligibility during a subsequent stability period. So in the case of a FT employee who drops to a PT position working less than 30 hours, while you could drop their coverage at the time of the status change, you would need to continue to measure them for the remainder of their measurement period. Then if at the end of the measurement period they have averaged 30 or more hours per week (including their FT and PT hours), you would be required to extend a new offer of coverage if they’ve previously been dropped, or extend their coverage throughout the entire stability period if they have not already been dropped.


To view the forms and instructions for filling them out follow the links below:

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