The HRA is not "affordable" because it is not a Health Plan. It is how an employer can participate in helping employees with health care costs or health coverage costs. Health Reimbursement Arrangement.

https://www.irs.gov/pub/irs-pdf/iw2w3.pdf

Explains the value reported isn't the same as Received, but Qualified to receive. It also explains: "Although a part of the permitted benefit is a taxable reimbursement, that does not change the amount you report in box 12 with code FF."

So, you need to find out everything that applies.

What you should first confirm is that taxpayer's health care coverage, though. Well, although MEC (minimal essential coverage) might not be applicable to prove to the employer, now that the penalty is gone? Hmmm. I'll have to look up these details.

@qbteachmt   "Affordable" for purposes of the Premium Tax Credit is a completely different thing than "affordable" for the penalty (which no longer exists).

@TaxGuyBill 

As always, I learn from the master. (bow)

Not sure if that is the right solution, but my understanding was that if it was considered affordable then taxpayer would not be eligible for any PTC, and your solution will give the same result - thanks!