Understanding Part II and Part III for Form 1094-C (2016)

Part II

22a. Qualifying Offer Method - 
To be eligible to use the Qualifying Offer Method for reporting, the employer must certify that it made a Qualifying Offer to one or more of its full-time employees for all months during the year in which the employee was a full-time employee for whom an employer shared responsibility payment could apply.

22c. Section 4980h Transition Relief -    

For the 2016 calendar year, the transition relief described below is applicable only if an ALE Member (or any other member of the ALE Member's Aggregated ALE Group, if applicable) offers coverage under a health plan with a plan year beginning on a date other than January 1 (a non-calendar year plan year), and only for calendar months in 2016 that fall within that 2015 plan year. Check this box if the ALE Member is eligible for section 4980H Transition Relief for one or more months of the 2016 calendar year under either:

  •  2015 Plan Year Section 4980H Transition Relief for ALEs with Fewer Than 100 Full-Time Employees, Including Full-Time Equivalent Employees (50-99 Transition Relief), or
  • 2015 Plan Year Transition Relief for Calculation of Assessable Payments Under Section 4980H(a) for ALEs with 100 or More Full-Time Employees, Including Full-Time Equivalent Employees (100 or More Transition Relief). 

22d.  98% Offer Method

To be eligible to use the 98% Offer Method, an employer must certify that taking into account all months during which the individuals were employees of the employer and were not in a Limited Non-Assessment Period, the employer offered, affordable health coverage providing minimum value to at least 98% of its employees for whom it is filing a Form 1095-C employee statement, and offered minimum essential coverage to those employees' dependents. 


Part III

(A) Minimum essential coverage

  • If the ALE Member offered minimum essential coverage to at least 95% of its full-time employees and their dependents for the entire calendar year, enter "X" in the "Yes" checkbox on line 23 for "All 12 Months" or for each of the 12 calendar months.
  •  If the ALE Member offered minimum essential coverage to at least 95% of its full-time employees and their dependents only for certain calendar months, enter "X" in the "Yes" checkbox for each applicable month.
  • For the months, if any, for which the ALE Member did not offer minimum essential coverage to at least 95% of its full-time employees and their dependents, enter "X" in the "No" checkbox for each applicable month.
  •  If the ALE Member did not offer minimum essential coverage to at least 95% of its full-time employees and their dependents for any of the 12 months, enter "X" in the "No" checkbox for "All 12 Months" or for each of the 12 calendar months.


However, for ALE Members with non-calendar year plans, an ALE Member that did not offer minimum essential coverage to at least 95% of its full-time employees and their dependents but is eligible for certain transition relief described in the instructions later under Section 4980H Transition Relief for 2015 Plan Years should enter an "X" in the "Yes" checkbox for Part III, column (a), for months to which the transition relief is applicable. This transition relief is available in 2016 only for ALE Members with plans with a non-calendar year plan year; for such an ALE Member, the relief applies only to the calendar months in 2016 that fall within the 2015 plan year. See the instructions later under Section 4980H Transition Relief for 2015 Plan Years.

(B) Full-time employee count:
If using the standard monthly measurement, you can measure this by calculating which employees have 
more than 130 hours per month of service. Do not include employees in a limited non-assessment period in this count, and if you qualify for the 98% offer method, you can skip this. (The BoomTax interface will automatically hide this column if you select the 98% offer method earlier in the process.)


(C) Total employee count:
Enter the total number of all of your employees, including full-time employees and non-full-time employees and employees in a Limited Non-Assessment Period, for each calendar month. 

An employer must choose to use one of the following days of the month to determine the number of employees per month and must use that day for all months of the year: (1) the first day of each month; (2) the last day of each month; (3) the 12th day of each month; (4) the first day of the first payroll period that starts during each month; or (5) the last day of the first payroll period that starts during each month (provided that for each month that last day falls within the calendar month in which the payroll period starts). 

If the total number of employees was the same for every month of the entire calendar year, enter that number in line 23, column (c) "All 12 Months" or in the boxes for each month of the calendar year. If the number of employees for any month is zero, enter "0".

(D) Aggregate group indicator
Select every month in which the ALE member was part of an aggregate ALE group.

(E) Section 4980h Transition Relief
Select the type of 4980h transition relief that applies to the ALE group. Only 1 type can be selected.

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