Question: I have Union employees, does that mean I should use the “Multi-Employer Interim Relief” (Code 2E) for the safe harbor for those employees?
Answer: Not necessarily. If the Union is sponsoring the plan, then yes, use the “Multi-Employer Interim Relief” (Code 2E) for the safe harbor for those employees. If the employer is sponsoring the plan, then use the safe harbor code that applies for the employer-sponsored health insurance plan.
Next Question: How do I know if the Union or the employer is sponsoring the health insurance plan for Union employees.
Answer: In situations where the employer is aware of when an employee enrolls into health insurance, then “generally speaking”, the plan is being sponsored by the employer. In contrast, when the employer has no visibility into who enrolls into the health insurance (it is maintained exclusively by the Union), then “generally speaking”, the plan is being sponsored by the Union.
Questions / Resources
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If you would like to search for information and resources for Integrity Data products check out the following sites:
- Knowledge Base: https://www.integrity-data.com/hrp/knowledge-base/
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Last Review: 3/6/2018 – Revision: 1.0
Applies To: ACA Compliance Solution
Categories: ACA Plan Setup, Import of Data, Year End – 1095-C and filing
Keywords: Union, 2E