Re: Affordable Care Act (ACA)

All:

Yesterday we applied the latest SAP note 2286950 in our quality environment and re-ran the 1095s.  This is what I found:

1. Employees who are not covered under our health plan due to Military LOA (active employment status) erroneously showing 2B in line 16 for the months not enrolled in our health plan, but still actively employed.
2. Rehires who waived coverage are now erroneously showing code 2B in line 16 for various months after rehire. 
   1. Employee A was Rehired 1/12/2015; Waived health coverage eff. 1/12/15; She is now showing 2B in line 16 for February -  May
   2. Employee B was Rehired 8/31/2015; Waived health coverage eff. 8/31/2015; She is now showing 2B in line 16 for September and October

This seems wrong to me.  I can't think of any circumstance where 2B would fit any of our scenarios. When employees terminate employment, we continue coverage until the end of the month.  We don't have any part-time employees.  Is anyone else seeing this after applying note 2286950?  Do you have a different interpretation of code 2B?

Thank you,

Cynthia Garza