Understanding Part II and Part III for Form 1094-C (TY 2021)

Form 1094-C - 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.

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. 

Form 1094-C - Part III

(A) Minimum essential coverage
This is used to indicate the months in which the ALE Member offered minimum essential coverage (MEC) to at least 95% of its full-time employees and their dependents.

  • For the months, if any, the ALE Member did not meet these requirements, select the "No" checkbox for each applicable month.
  •  For the months, if any, the ALE Member met these requirements, select the "Yes" checkbox for each applicable month.

(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 (waiting period) in this count.

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 (full time, part time, seasonal, temporary, in a waiting period, etc.) 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).

(D) Aggregate group indicator
Select every month in which the ALE member was part of an aggregate ALE group. Then complete Part IV regarding other members of the aggregate ALE group.

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