ACA Reporting using "1A" and Penalty has been applied

My client utilizes "1A"  in ACA Reporting for all FT employees because they all are offered MEC that provides minimum value and the cost for EE only coverage is $0. They also over coverage for the dependents and spouse.

It is our understanding that when "1A" is utilized that Line 16 is left blank.

Most of the employees actually receive "1A" in the all month column. They have a custom program that populates that for all FT employees that have been FT for the full 12 months.

What we are seeing - there were a few new hires in the calendar year - we reported the 1H and 2A for the months prior to hire. Once the employee was hired (or status changed from PT to FT) they used 1H and 2D for their Limited Non-Assessment Period. The month they become eligible for coverage - they change the code to 1A since all employees are offered full coverage at no cost. Line 16 is blank. The employee can WAIVE coverage providing they have proof of other coverage. They still use 1A - because they were offered it.