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ACA Affordability Changes for 2024
Each year, the IRS adjusts the percentage that is used to determine affordability. The IRS just announced that for plan years that start on or after January 1, 2024, the affordability rate will be set at 8.39%. This represents a significant reduction from the previous year’s 9.12%.

Employers subject to the ACA employer mandate need to check their contribution rates for each plan year to ensure their offers of medical coverage to their full-time employees are affordable. If the offers of coverage are not affordable, the IRS assesses a penalty to the employer for each full-time employee who has Marketplace coverage with tax credits.

This affordability rate represents the maximum percentage of household income that an employer can charge full-time employees for self-only coverage in the lowest cost medical plan for the offer to be deemed affordable. Since employers do not know their employees’ household income, the IRS allows them to use one of three affordability safe harbors. The affordability safe harbor that the employer adopts is used for its annual Form 1095-C reporting.

For plan years starting in 2024:
Federal Poverty Level (FPL)
If the self-only employee contribution is at or below 8.39% of the federal poverty level, the offer is affordable. (For 2024 plan years, this equates to $101.93 or less per month, which is a reduction from the 2023 plan year limit of $103.28.)

Rate of Pay
If the self-only employee contribution is at or below 8.39% of the employee’s monthly pay rate, the offer is affordable. For full-time hourly employees, the employee’s hourly pay rate is multiplied by 130 hours, regardless of actual hours worked. Tips, commissions, and other variable pay cannot be included when using this safe harbor.

W-2 Box 1 Wages
If the self-only employee contribution is at or below 8.39% of the employee’s Box 1 wages, the offer is affordable. This can only be determined at the close of the calendar year.
If your organization is subject to the ACA employer mandate, please work with your OneDigital account team to ensure your full-time employees are offered medical coverage with an affordable contribution.

For more information, please view our article: IRS Decreases 2024 ACA Affordability Percentage to 8.39%.
If you have any questions, please contact your OneDigital account team. Do not reply directly to this email address.
Upcoming Compliance Deadlines
SAR to Participants for Calendar Year Plans
by September 30, 2023

Distribute Notice of Creditable Rx Coverage
by October 15, 2023

Medicare Part D Rx/Part C Open Enrollment
October 15, 2023 - December 7, 2023
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