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Re: Affordable Care Act (ACA)

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I'm not sure about the 2Fs and 2Hs that have been commented on.  The descriptions for both of those codes appear to me to indicate how the employer determined affordability.  I'm not sure that's appropriate to affordable plans that should have 1A on line 14.  The IRS's own instructions also state "If none of the codes apply for a calendar month, leave the line blank for that month."  So, I don't know that that's a particularly bad thing to do nor would trigger an audit.

 

I wouldn't think the 1E/cost/2F is right, though.  The distinction between 1A and 1E seems to be one of affordability.  If the same, affordable coverage is offered to two employees, I think they should both get 1A and cost need not be reported.  We're using 1E/Cost for plans that don't meet the 9.5% definition of affordability, e.g. plans offered to those on unpaid leave, COBRA, part-time employees, and retirees.

 

This is all rather confusing, and I'm not a lawyer, so I'm just explaining our reasoning here, not necessarily saying the others are wrong.  But, the above is bascially how we ended up determining to use 1A/blank for the waives.

 

Ashwini's correct, too, though about the work required with implementing the BAdI, and about defining the waive plans in *_ASPCC.  I can't remember how the standard code treats those WAIVs, though.  I'm pretty sure our BAdI implementation changes the original codes.

 

Alex


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