1A (Series 1) always has blank 2 series. We think we should have some 2C's

My Benefits manager is questioning why 2 series is blank for our 1A's.  We have 2000+ people who have 1A the whole year and had medical coverage the whole year. But their 2 series is blank.

He understands the rate (line 15) being blank for 1A, as 1A is not one of the codes listed requiring a rate.

He understands the 2 series being blank if no defined definitions are met, or if 2C is met and meets the criteria to not report 2C.

However these employees we think should be 2C as they are covered, and don't meet the criteria for when not to report 2C. We see that one of the criteria to not report 2C is even if covered, if not offered minimum essential coverage don't report 2C. But the definition of 1A means they have minimun essential coverage, just low rate: