Critical Human Resources update available

A last minute critical bug has been found and corrected today, and an update is now available through the Check for Updates option.  All customers must update to version 7.57.322 to insure that 1095-C forms for all employees that should receive one are printed mailed by the due date of March 31.

Due to the penalty involved in not providing a 1095-C to an employee ($250 per employee) it is very important to install this update and make sure that all forms have been printed and mailed to employees.

The bug involves employees that have full time status only for the month of December.  These employees may not be included when 1095-C forms are printed.  The Full Time checkbox that is at the top of the Enter/Edit 1095-C Form should have been checked for these employees when the 1095-C record was created and it was not.  Since it was not checked, by default a form was not printed.

Affordability Safe Harbor fix available

In a previous post today, we explained the incompatibility between using the 1A code on line 14 and the 2F or 2H code on line 16.  Tonight’s update (version 76.57.322) includes an option to automatically make changes to eliminate the conflict between the two codes on all of the 1095-C forms where both are used.  This eliminates the need for you to edit each form manually.

By simply running the 1095-C Report for full time employees, the program will detect any employees that use both codes, and if any are found, you will get a message similar to the following:

To decide what you should do, you must first know what affordability safe harbor you used.

(Sorry, but we can’t help you decide what method you used to determine affordability of your plan.  The only recommendation we can provide is that if your plan does not require any contribution from the employee, the simplest thing seems to be using the federal poverty line safe harbor.)

If you are using the federal poverty line safe harbor, then you want to keep the 1A code.  That means that you either need to report 2G on line 16 (which as we explained previously, is redundant) or blank out the line 16 code for months in which you are reporting a 1A code on line 14.  The last two buttons on the right provide you with each of these options.

On the other hand, if you did not use the federal poverty line safe harbor, you will need to change the 1A code to a 1E code on line 14.  The middle button provides you with that option.

You can also choose to do nothing.  You can re-run the report again and the same message will appear.

Clicking on the “Help!” button will simply take you to the previous blog post about this issue.

For future years, when the 1A code is in use, we will like

 

 

Conflicting 1095-C Affordability Safe Harbor codes

“A safe harbor is a provision of a statute or a regulation that specifies that certain conduct will be deemed not to violate a given rule. It is usually found in connection with a vaguer, overall standard.” — Wikipedia

Update 3/30/16:  A new post explains the options available for eliminating conflicting affordability safe harbor codes.  This is available in version 7.57.322 and higher, available now using the Tools->Check for Updates option.

Last week, while reviewing one of our customer’s 1095-C forms, an insurance company pointed out that the 1A code used on line 14 conflicted with the 2H code that they had used on line 16.  The 1A code says that you used the federal poverty line method for the affordability safe harbor while the 2H code indicated that they rate of pay method was used.

First a quick refresher:  what is the affordability safe harbor?  The ACA says that employers must offer self only coverage to employees that is “affordable”.  In the law, affordable is defined as no more than 9.5% of household income.  The problem is that employers have no idea what an employee’s “household income” is.  First of all, household income is determined after the end of the year when the employee is filling out their tax return, so it is not even known at the time that decisions about coverage costs and offers are being made.  Second, the employee never reports their household income to their employer!