Reporting Offers of Coverage – 1A versus 1E
Benefit Comply can review your reporting to help identify where there a risk of penalty under §4980H (the “employer mandate”). More Info >
When reporting offers of coverage in Part II, Line 14 of the Form 1095-C, both codes 1A and 1E indicate an offer of minimum value coverage that is made available to the employee, spouse and children. The difference is tied to whether the employee contribution meets the FPL safe harbor.
1E = a minimum value offer of coverage to employee, spouse and children
1A = 1E + the offer meets the FPL safe harbor (also referred to as a “qualifying offer”)
If the employer offers minimum value coverage to employees, spouses and children that meets the FPL safe harbor, it is considered a “qualifying offer”. When that is the case, the employer has two options for coding offers of coverage on Line 14 the Form 1095-C:
- Mark the “Qualifying Offer Method” on Line 22 of the Form 1094-C, and then use Code 1A on Form 1095-C (Line 14) and leave Lines 15 and 16 blank; or
- Use Code 1E on Form 1095-C (Line 14), enter the contribution amount on Line 15, and enter Code 2G on Line 16.
Either way is correct. Using 1A just simplifies the reporting a bit in that Lines 15 and 16 can then be left blank.
NOTE: 1E could be paired with any of the affordability safe harbor codes (i.e., 2F, 2G, or 2H).