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ACA - IRS-Allowed Non-Offer Scenarios Counting against MEC % Check on Form 1094-C (Doc ID 2614557.1)

Last updated on JANUARY 15, 2020

Applies to:

Oracle Advanced Benefits - Version 12.1 HRMS RUP11 and later
Information in this document applies to any platform.


On R12.1 HRMS Rup10, Affordable Care Act Archive Reporting

This Note explains an issue where 1H/2D and 1H/2A  (Line 14/Line 16 codes) were being taken as non-offers
     - Even when those codes were from employees who were:
          - Transferring between GRE's within the reporting year (1H/2A)
          - New Hires with Waiting Periods (1H/2D)

Actual Results:
When Producing 1094-C for Set of GREs where there is a high New Hire ratio each month
   - 1H codes where Line 16 = 2D (Wait Period) are not being ignored when assessing
      Offer percentage to compare against the 95% Qualifying Offer Method to set
       the MEC/MV Indicator on the 1094-C.

This occurs on the archive process when archiving GRE data.

Expected Results:

Expected REsults would be to NOT have these scenarios count against the GRE on the MEC % Offer Check that is reported on Form 1094C

IRS Excerpt from the 1094/1095 instructions page (Page 8 - middle of right column)

For purposes of column (a), an employee in a Limited Non-Assessment Period is
not counted in determining whether minimum essential coverage was offered to
at least 95% of an ALE Member's full-time employees and their dependents.

For a description of the differences between the definition of the term
Limited Non-Assessment Period used with respect to section 4980H(a) and the
definition used with respect to section 4980H(b), relating to whether the ALE
Member offers minimum value coverage at the end of the Limited Non-Assessment
Period, see the Definitions section.





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