The code “2D” is the IRS ACA 1095-C Line 16 code for “Employee in a section 4980H(b) Limited Non-Assessment Period for the month.” This means that the employee was either in their waiting period (new full-time employee) or initial measurement period (new variable hour employee).
The Non-Assessment Period maximum allowed by the IRS is up to 3 full months after the hire month for a new full-time employee. If this is selected, then the 1095-C would show 4 months with a 2D on line 16. For example, if a full-time employee was hired on 7/2/2015 the employee is in their Non-Assessment Period from July through November. To correlate with this time period, a 2D will appear in the months of July through November on Line 16 of the 1095-C form and a corresponding “1H” will appear in Line 14.
However, the Cloud solution allows you to put in your exact situation in the Company setup in Configuration and from that the 1095-C will properly fill your company’s months of waiting for those full-time. For example if you check Start of Month and then select 1 month in the dropdown, the 1095-C for the example above would put a 1H/2D for July and August.
If your company offers insurance immediately on hire, you would select none of those above. If your company offers insurance at the start of the next month after hire, you would only check Start of Month and put 0 in Number of Months. If you have a set days of waiting you would uncheck the Start of Month and then enter your Waiting Period Days up to a maximum of 90.
If you are Self-Insured, Part III is determined by the months that you upload with a Deduction (2) and/or Benefit (3) for Health Insurance in the transactions. If you do not have a transaction showing a month when they are covered, then the box for that month in Part III will not be checked. Click Here for more information .
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Last Review: 5/17/2017 – Revision: 2.0
Applies To: ACA Reporting Requirements, ACA Compliance solution