ACA 1095 BEST PRACTICES:
AUTOMATED LINE 15 MONTHLY PREMIUM AMOUNT
Definition – A technology-based approach for automatically determining and assigning the appropriate 1095-C, Part 2 Lowest Monthly Premium for Single Only Coverage for each of the 12 months for each respective recipient and covered individual.
Rationale – The penalty for putting the wrong Lowest Monthly Premium for Single Only Coverage in Line 15 is $250 per incorrect form.
Examples of Line 15 of Lowest Monthly Premium for Single Only Coverage follows:
1. Wrong Amount – As the name implies, the dollar figure that goes in Line 15 is the Lowest Monthly Premium for Single Only Coverage. This box pertains to the amount of the most affordable plan regardless of whether the employee elected it (i.e., if the employee selected a more expensive plan, the lowest plan cost is entered).
2. Wrong Amount Pay Frequency – Again, even though the name states “monthly premium” it is important that the actual monthly, not the weekly or bi-weekly cost is used.
3. Code Conflict – When certain Line 14 Offer of Coverage Codes are used (e.g., 1A – Qualifying Offer), line 15 should be left blank. Conversely, when other codes are used, such as 1E – MEC, MV, rate exceeds $93.18 in 2015) line 15 should be populated. In addition, in months where no offer of coverage has been made (1H), line 15 should also be blank.
- Review source data.
- Develop metric estimates (i.e., if every Line 14 is a 1A, the summation of monthly premiums should be blank).
- Run test data.
- Compare actual results to estimates.
- Refine software and re-test.
Since 2016 is no longer a “best efforts” year, employers should embrace best practices or simply accept the dire likelihood of material penalties. In order to mitigate future risks employers should thoroughly review and improve their supporting processes and technologies. Employers have the opportunity to fortify their environments and avoid penalties. As they say, “there’s no time like the present – do it now!”