New 2016 ACA Reporting Codes on Form 1095-C

The draft regulations for 2016 ACA reporting have been released and with those instructions have come two new codes for consideration in part II of the form 1095-C.  Specifically these are for line 14 of the form 1095-C, the offer of coverage, and they introduce a new concept to the reporting of a conditional offer of coverage.

A conditional offer of coverage is an offer of coverage that is subject to to certain conditions which would impact the availability of coverage for the spouse of an employee.  One example of a conditional offer of coverage would be if an employer offered health coverage to an employee and their spouse, unless the spouse was otherwise eligible for another group health plan sponsored by another employer.

Code 1J

Code 1J is used on line 14 of form 1095-C when an employee was offered coverage for all days of the month which:

  • Provided minimum essential and minimum value to the employee, and
  • Provided at least minimum essential coverage to their spouse that was a conditional offer, but
  • Did not provide coverage to the dependents of the employee

Code 1K

Code 1K is used on line 14 of form 1095-C when an employee was offered coverage for all days of the month which:

  • Provided minimum essential and minimum value to the employee, and
  • Provided at least minimum essential coverage to their spouse that was a conditional offer, but
  • Did provide coverage to the dependents of the employee