One thing we forgot to mention in the first post in this series is to make sure (if at all possible) that you have entered a date declined on all decline records. It is better for your records to have this date on file (either when coverage was offered to the employee or when you received their paperwork declining coverage). If a decline record is missing a date declined, then the program will assume that it was entered before the employee was eligible for coverage and base the logic for line 16 codes on that assumption.
A year ago when customers were pre-enrolling employees, it was not clear that entering a date would be helpful, so we told customers that it was optional. The important thing was to get the decline record entered so that the employee did not get automatically enrolled in coverage.
Early this year, when entering a decline record we changed the “Date Offered” to read “Date Declined”, added the date entry to the Add Decline Coverage Records window, and started recommending that customers enter that date when recording a decline record.
As we move forward and multiple years of coverage will be tracked in the program, it will be required to enter this date for both coverage and decline records. Since employers must provide an offer of coverage to employees each year, decline records that are over a year old will stop applying to employees on the Hour Eligibility Report. When an employee’s coverage choice expires, you should provide them with a new opportunity to accept or decline coverage for 2016.
Ambiguous Coverage Records
Another thing to watch for is coverage records that do not tell the program any useful information. A record where the Declined Employee Coverage checkbox is not checked and there are no coverage dates tells the program nothing except possibly that the employee was offered coverage, but either never returned the insurance forms or the employee’s selection was never entered into the program. We will be adding a report to find these records. Since they do not tell the program any useful information for 1095-C reporting purposes, they will not hurt anything if they are left in the system. But if an employee actually declined coverage and this was never properly recorded, then the system will not be able to report the correct codes on line 16.