ACA Reporting | Tate Computer Services

Affordable Care Act Reporting

The ACA Reporting module is part of the TCS Payroll System but can also be used as a stand alone module.

TCS has been successfully filing the 1095-C form since 2015 when the requirement began.

Below is an excerpt from the instruction for using the system.

We will make the following assumptions to simplify the pre-filling of the form with certain defaults -

Assumption1 – You offer Healthcare Coverage to all full time employees and their spouses and dependents – and – you meet the requirement of a Qualifying Offer. (The employee pays equal to or less than $93.18 per month for self-only coverage.)
Assumption2 – You offer Healthcare Coverage to all full time employees and their spouses and dependents – and – you do not meet the requirement of a Qualifying Offer. You do not meet the requirement of a Qualifying Offer only because it is not considered Affordable by the ACA – meaning the employee pays more than $93.18 per month for self-only coverage. But the plan does provide Minimal Essential Coverage (MEC) and Minimum Value (MV).

We will not cover the cases where the plan does not provide MEC and MV.

Part 2 has three Lines to fill out

Line 14 – Offer of coverage (Affordable or Not Affordable)
Line 15 – Employee share of monthly premium (if not Affordable)
Line 16 – Safe Harbor codes for the time before and after employment and the waiting period before coverage is offered. The codes are also for months when the employee declines coverage.

We will pre-fill the form for the 4 most common cases

Qualifying Offer (Assumption1) and the employee is covered for all 12 months of the year.
Qualifying Offer (Assumption1) and the employee is covered for only part of the year and has months before and/or after the covered period that do not include coverage.
Non-Qualifying Offer but MEC (Assumption2) and the employee is covered for all 12 months of the year.
Non-Qualifying Offer but MEC (Assumption2) and the employee is covered for only part of the year and has months before and/or after the covered period that do not include coverage.

1 – Assumption 1 (Qualifying Offer) with 12 months of Coverage

Line 14 – Contains code 1A in box 1 and the remaining 12 boxes are blank.
Line 15 – All zero.
Line 16 – Contains code 2C in box 1 and the remaining 12 boxes are blank.

2 – Assumption 1 (Qualifying Offer) with Less than 12 months of Coverage

Line 14
- For each month prior to coverage we place code 1H.
- For each month of coverage we place code 1A.
- For each month after coverage we place code 1H.
Line 15 – All zero.
Line 16
- For each month prior to coverage (not employed) we place code 2A.
- For each month of employment in the waiting period, we place code 2D.
- For each month of coverage we place code 2C.
- For each month after coverage (not employed) we place code 2A.

3 – Assumption 2 (Non-Qualifying Offer) with 12 months of Coverage

Line 14 – Contains code 1E in box 1 and the remaining 12 boxes are blank.
Line 15 – Contains the Employee share of Lowest Cost Monthly Premium for Self-Only Minimum Value Coverage in each of the 12 monthly boxes. (These are entered once by you into our setup file and are the same for all employees)
Line 16 – Contains code 2C in box 1 and the remaining 12 boxes are blank.

4 – Assumption 2 (Non-Qualifying Offer) with less than 12 months of Coverage

Line 14
- For each month prior to coverage we place code 1H.
- For each month of coverage we place code 1E.
- For each month after coverage we place code 1H.
Line 15 – Contains the Employee share of Lowest Cost Monthly Premium for Self-Only Minimum Value Coverage in each of the months of coverage. (These are entered once by you into our setup file and are the same for all employees)
Line 16
- For each month prior to coverage (not employed) we place code 2A.
- For each month of employment in the waiting period, we place code 2D.
- For each month of coverage we place code 2C.
- For each month after coverage (not employed) we place code 2A.

Notice that filling out Part 2 for our 2 Assumptions is very simple and may cover the majority of your employees. You may or may not have exceptions that require evaluation of individual cases.

One exception to consider is if the employee declines coverage for any reason. Further below we suggest how the form should be filled out and provide a copy of a sample form for this exception.

Another exception to consider is when an employee chooses to continue coverage under COBRA.

A large portion of the instructions are for cases that do not match our 2 assumptions. For example coverage is not offered to the employee or their spouse and dependents. Or the insurance plan does not meet the criteria of a Qualifying Offer because it does not meet MEC or MV. If these 2 criteria are not met, filing out the 1095-C becomes very complicated. But our software solution will allow you to complete the form for any scenario.

If you want to research further how we came to our interpretation of the instructions, see the section below describing each of the Lines 14, 15, and 16.