ACA Codes: Explanations and Tips

OVERVIEW

ACA codes provide employers with a way to categorize the medical benefits they offer their employees and the scenarios in which benefits were offered to them. This guide provides a list of codes, what they mean, when they should be used, and other items to consider when using each code.

1 CODES

Code Series 1 is used for Line 14 of Form 1095-C.

Code	What does this code mean?	When should it be used?	Things to consider
1A	A Qualifying Offer was made by the employer to the employee, their spouse, and dependents. Minimum Essential Coverage (MEC) with Minimum Value (MV) was made. The offer is affordable because it’s < or 9.5% of the single, mainland federal poverty line.	Coverage was offered to the employee, their spouse, and dependents. MEC was offered, providing MV Coverage that was offered is considered affordable at the employee-only level.	This code is contingent on the option selected under the Safe Harbor section of the ACA Info Page.
1B	MEC was offered to the employee only and provides MV.	Coverage is only offered to the employee and not their spouse or dependents.
1C	MEC that provides MV was offered to the employee and their children.	Coverage is only offered to the employee and their children, but not their spouse
1D	MEC that provides MV was offered to the employee and their spouse.	Coverage was offered to the employee and their spouse, but not to their children.
1E	MEC that meets minimum value was offered to the employee, spouse, and children.	The difference between codes 1E and 1A is that the coverage may not be considered affordable based on the Financial Poverty Line Safe Harbor method.	This code is contingent on the option selected under the Safe Harbor section of the ACA Info Page.
1F	MEC is offered to the employee or employee + spouse and/or dependents but the coverage does not provide MV.	The coverage offered does not meet the MV threshold.	Review ACA Info Page to determine if MV is selected for the appropriate plans.
1G	Self-insured coverage was offered to an individual who is not full time at any point in the year,	A self-insured plan is offered. Non-full-time individuals are eligible for the plan. The employee was enrolled in the plan at some point in the year. Not employed during the calendar year.	This may apply to someone who is part-time but still receives coverage. This may also apply to an individual who is not currently employed but is enrolled in COBRA.
1H	No offer of coverage was made (or one was made, but it did not meet the MEC threshold for the employee).	The employee was not hired yet. The employee was in a limited-assessment period. The employee was otherwise ineligible for coverage. The offer of coverage was not MEC. The offer of coverage was not for an entire month. The employee was terminated and was offered COBRA.	This could indicate that the employee was not employed for a particular month, or was not eligible for a particular month. This code may also indicate that the MEC was not selected for the corresponding plan on the ACA Info Page.
1J	MEC that provides MV was offered to the employee and their spouse, as well as coverage conditionally offered to spouse (not dependents).	Conditionally offered to a spouse. Coverage was not offered to dependents.
1K	MEC that provides MV was offered to the employee, their spouse, and children, as well as coverage conditionally offered to a spouse.	Conditionally offered to a spouse. Coverage was offered to dependents.

2 CODES

2 Codes are used for Line 16 on Form 1095-C.

Code	What does this code mean?	When should it be used?	Things to consider
2A	The employee was not employed during this month.	The employee has not yet been hired. The employee is no longer employed
2B	The employee was not full-time during this month.	The employee was part-time. The employee was a seasonal or variable hour worker. The employee is in a measurement period and full-time status has not yet been established.
2C	The employee has accepted and enrolled in the coverage offered.	The employee is enrolled in coverage offered by the employer.	In order to generate this code, coverage must be active for the entire month.
2D	The employee was in a Limited Non-Assessment Period (LNAP) for this month.	The employee is in a waiting period under the look-back measurement period. The employee is in the first calendar month of their employment and did not start on the first day of the month. The employer is in their first year as an Applicable Large Employer (ALE). The employee has a status change during their initial look-back measurement period.	This code will populate during a new hire’s waiting period. It’s important to note that even if there is a Department of Health wait period, this code will still generate unless the employee is hired on the first day of the month.
2E	The employer is eligible for the multiemployer interim relief rule.	Some portion of the workplace is eligible for a multi-employer (union) plan. The employer makes an ongoing contribution to the plan on behalf of union employees.
2F	The coverage offered is affordable based on the W-2 Safe Harbor method.	Coverage is considered affordable for this employee based on the W-2 Safe Harbor method. The W-2 Safe Harbor was used for every month that the employee was offered coverage.	Coverage was offered, however, the employee waived coverage. The difference between 2F, 2G, and 2H is the Safe Harbor selection on the ACA Info Page.
2G	The coverage offered is affordable based on the Federal Poverty Line Safe Harbor method.	Coverage is considered affordable for this employee based on the Federal Poverty Line Safe Harbor method.	Coverage was offered, however, the employee waived coverage. The difference between 2F, 2G, and 2H is the Safe Harbor selection on the ACA Info Page.
2H	The coverage offered is affordable based on the Rate of Pay Safe Harbor method.	Coverage is considered affordable for this employee based on the Rate of Pay Safe Harbor method.	Coverage was offered, however, the employee waived coverage. The difference between 2F, 2G, and 2H is the Safe Harbor selection on the ACA Info Page.

ADDITIONAL INFORMATION TO CONSIDER

Code 2C

This code displays the cost of the cheapest medical plan offered by the employer at the Employee Only. It does not reflect the employee’s specific plan rate or plan level information.

Code 2C most commonly populates with 1E, however, the following codes may trigger code 2C as well:

Code 2E

Enter the employee’s zip code each month
Only applies if the company offers an HRA plan
If no HRA plan is offered, the field will remain blank.

Part Three: Covered Individuals

This section is only applicable for Self-Insured organizations.

Line 15

Line 15 displays the cost of the cheapest Medical plan on the Employee Only level offered by the employer. It does not reflect the employee’s specific plan rate or plan level information.

Line 15 most commonly populates with 1E, however, the following codes may trigger Line 15 as well:

Line 17

Enter the employee’s zip code each month.
Only applies if the company offers an HRA plan.
If no HRA plan is offered, the field will remain blank.