ACA 1095C Line 14 for mid-year Retiree offers showing 1H
We use OAB - Currently our employees who retired in 2016 show 1H on Line 14 and 2A on line 16 starting the month after they retire. However our retirees are eligible for retiree benefits and we process a Retirement LE for them during that month, where they do have electable choices in a qualifying self-insured plan (the setup on the plan is the same as the employee plan). Since we do make an offer to them, we expected to see whatever their previous 1A/1B code is continue through the end of the year?
Wanted to check and see if 1H is the expected code for this scenario? The 2A makes sense for line 16 since they are no longer employed, but we have made an offer to them so 1H does not seem correct for line 14. Retirees who were retired for the entire year and offered the same plan display as 1G for all 12 months, so for them it is recognizing an offer was made.