Version 7.53.286 is available for download now. The release notes includes a list of the changes, but we wanted to highlight two critical changes for certain employers:
New logic has been added to the Compile 1095-C Information option to handle ALE Groups. When you have multiple companies that are reporting as a group, you must compile the 1095-C information for each ALE Member.
The program will now determine which employer will report for each month for each employee. If an employee worked for two or more employers in the same month, the employer with the most hours will be the one to report the employee. The other employers will have a “1H” code reported on line 14 and a “2A” code reported on line 16. These codes in combination tell the IRS that either the employee did not work for that employer in the month or that employer is not reporting the employee for that month.
When you place the mouse pointer over the “2A” code for a given month, the tooltip will either show “No hours for this month”, which indicates that the employee did not work for this ALE Member for that month, or “Reported by another group member”, which indicates that the code for that month will be reported by another ALE Member.
Each ALE Member is required to issue a 1095-C to the employee if the employer is reporting that the employee was full time for one or more months. This means that the employee should not receive a 1095-C from an ALE member if the only months that ALE Member has to report are not full time. (The 1095-C record will still be generated, it just won’t be printed.)
The logic has also been extended to look at the health benefit records in all ALE Members to determine coverage and decline information. So if an employee is being reported for a given month by ALE Member #1, but was enrolled in coverage in ALE Member #2, the program will pick up that coverage information and report the 2C code in the months in which the employee was enrolled. The same applies for decline records.
While we have tested this new compile process in house with customer files that are set up as an ALE Group, ALE Group reporting adds another layer of complications on top of an already complicated process. We strongly suggest customers apply extra scrutiny to the forms generated before distributing them. You can print the actual forms by Social Security number to collate forms for each employee from different ALE Members and compare them to make sure that all months are being reported correctly by your ALE Members.
An ALE Group Line 16 report is planned that will show which ALE Members are reporting for each month along with the codes that are reported by each member. However, this report will not be completed until next week, so for the present time, printing the forms for each ALE Member and reviewing these is the best available option.
Salary Employees – Actual Hours of Service
If you are tracking actual hours worked by salary employees to determine their full or part time status, update to the current version and recompile any salary employees. The logic that added up the hours needed to be corrected, and salary employees may have been incorrectly classified as part time employees on the 1095-C due to this.
If you are using the Days Worked or Weeks Worked equivalency methods, no changes were required.