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July 25, 2019
In Revenue Procedure 2019-29, the IRS decreased the affordability percentage from 9.86% to 9.78% for 2020. This percentage determines which applicable large employers may face penalties under §4980H(b) for failure to offer affordable coverage as well as which individuals may qualify for subsidized coverage through a public Exchange.
Under §4980H, applicable large employers (50 or more full-time equivalents (FTEs)) must offer coverage to full-time employees that is affordable to avoid potential §4980H(b) penalties. In addition, individuals enrolling for coverage through a public Exchange will not qualify for subsidized coverage if they are eligible for employer-sponsored group health coverage that is affordable.
Coverage is generally considered “affordable” if the employee contribution for employee-only (single) coverage does not exceed a set percentage (9.78% in 2020) of household income. Note – Coverage is considered affordable for dependents as well, regardless of the contribution amount, so long as the employee-only (single) coverage is affordable. Coverage is also considered “affordable” for purposes of satisfying §4980H(b) requirements so long as the employee contribution satisfies at least one of three available safe harbors (i.e., federal poverty level (FPL), rate of pay, or Form W-2).
Originally, for 2014, the required contribution percentage for determining affordability was set at 9.5%. The percentage is adjusted annually. See applicable percentages for each year in the table below.
Effective for plan years beginning on or after January 1, 2020, the percentage to be used in affordability calculations is 9.78%. This is true regardless of whether the affordability is determined based on household income or using one of the three affordability safe harbors. This percentage is also used to determine whether an employer made a “qualifying offer” for employer reporting purposes on Forms 1094-C and 1095-C.
The decrease in the affordability percentage (from 9.86% in 2019 to 9.78% for 2020) may require employers to charge slightly lower employee contributions for the 2020 plan year and still meet affordability guidelines under §4980H(b). For more details about affordability considerations and use of an affordability safe harbor, see our issue brief on affordability found at https://www.psfinc.com/articles/affordability-consideration/, or contact your PS&F Benefits team to discuss any impacts this will have your benefit plans.
As always, should you have any questions, please contact your Parker, Smith & Feek Benefits Team. For additional employee benefit compliance news and information visit our Healthcare Reform Explained website.
The views and opinions expressed within are those of the author(s) and do not necessarily reflect the official policy or position of Parker, Smith & Feek. While every effort has been taken in compiling this information to ensure that its contents are totally accurate, neither the publisher nor the author can accept liability for any inaccuracies or changed circumstances of any information herein or for the consequences of any reliance placed upon it.