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2024 ACA Affordability Rate Impact on Large Employers

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Brooke Salazar, JD Sr. Director of Compliance profile photo
By Brooke Salazar, JD Sr. Director of Compliance
 on September 5, 2023
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The IRS released a new (and reduced!) ACA Affordability Rate for 2024.

Employer sponsored health coverage for a 2024 calendar plan year will be deemed โ€œaffordableโ€ when the employee required contribution for self-only coverage does not exceed 8.39% of the employeeโ€™s household income for the taxable year. Employers using the exact safe harbor dollar amount will have a smaller employee contribution for the lowest-cost, self-only option for the 2024 plan year than for the 2023 plan year. This in turn means employers will make a larger contribution to meet the affordability threshold.

Pro Tip: In this context, safe harbor means a method for proving ACA affordability to avoid penalties.

What does this mean for employers?

An applicable large employer (โ€œALEโ€) may use one or more of the safe harbors, but only if the ALE offers 95% of its full-time employees (โ€œFTEโ€) and their dependents the opportunity to enroll in coverage that provides minimum value for the employerโ€™s lowest cost self-only coverage offered to the employee.ย  Employers may use one or more of the three affordability safe harbors (provided it does so on a uniform and consistent basis for all employees in the same category):

  1. Form W-2, Box 1 wages,
  2. Rate of pay safe harbor, and
  3. Federal poverty line (โ€œFPLโ€) safe harbor

Form W-2, Box 1 Wages

To meet the Form W-2, Box 1 wages safe harbor, the employee contribution cannot exceed 8.39% of the employeeโ€™s wage for the months of coverage offered. Often, the lowest paid employeeโ€™s W-2, Box 1 wages are used for this type of affordability analysis, depending on the organization and its constraints.

Letโ€™s do the math!

(0.0839 x $35,000 (example of annual Box 1, Wage) /12 months = $244.71 per month

FPL Safe Harbor for 2024 Calendar Year Plans

To meet the FPL safe harbor, the employee contribution cannot exceed 8.39% of the FPL for an individual for mainland U.S. ($14,580 for 2024).ย  Employers should note again this is a decrease from the 2023 plan year.

Letโ€™s do the math!

(0.0839 x $14,580) / 12 months = $101.94 per month

Hereโ€™s an Example:

  1. Toby is employed by Dunder Mufflin from January 1 through September 30 and his W-2 wages are $18,000.
    • The employee contribution for self-only coverage is $100 per calendar month, or $900 for Tobyโ€™s period of employment.
    • Because the employee contribution for 2024 is less than 8.39% of the Form Wโ€“2 wages, the coverage offered is treated as affordable with respect to Toby ($900 is 5 percent of $18,000).