If your company has multiple divisions,[1] it is not uncommon for employees to transfer from one of those divisions to another. When they do, it is necessary to enter a change line, so the IRS is notified they are now receiving insurance through another tax entity.


Division Change with the Same Plan

Even if the employee remains on the same plan, it is necessary to document the division change and change in coverage (because it is being provided by a different tax entity):



Here are the key details you’ll need to capture:

  • Term Date: For reporting purposes, the Term Date field is used to represent the date the employee “left” their first division.
  • Hire Date: The line 2 Hire Date should be the date the employee began at the new division.
  • Status Begin Date: This should match the Hire Date in the second line. Even though the employee still has the same Job Status, their location changed, so we need to note it here.
  • Division: The first line should refer to the employee’s original division, while the second line should list their new division.
  • Coverage Type: Be sure to select whether coverage was “Insured” or “Waived” both before (line1) and after (line 2) the change.
  • Coverage Type Dates: Make sure your coverage dates do not overlap. In most cases, the new Coverage Begin Date (line 2) will be day following the original Coverage End Date (line 1).



Division Change with a New Plan

If the employee is moving to a division that offers a different lowest cost plan, you need to note the employee’s plan change as well:



  • Plan ID: List their original plan in line 1, and their plan at the new division in line 2.
  • Everything else in this scenario should be coded in the same way as a Division Change with the Same Plan (above).



Next Step: Documenting Employee Leave



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[1] Division – For the purpose of ACA reporting, Division refers to a sub-set of a company with its own unique Tax ID. If an employee moves from one department/location to another, but the division they work for still has the same Tax ID, you do not need to report this change.