Hi Tania,
We don't have issue with line 16 Blank for EEs who changed plans mid-month (from a Regular plan to another Regular plan i.e. Blue Shield to Kaiser, or from a Waived plan to Regular plan i.e. Waived to HealthNet). We do have what you described as Blank on line 16 on the month that the EE changed from a Regular plan to a Waived plan mid-month (i.e. Kaiser to Waived). Our definition of mid-month is that the dates in IT0167 follow the pay period dates. The new note 2294706 ACA Mid-month Actions did not correct this particular issue for us. We have incident 28169 opened for this.
Fortunately, we only have 7 EEs in this situation. To get the forms out on time, we manually created the forms in Adobe by using the blank IRS form 1095C & fill in the EE info. Hopefully, these EEs will be corrected to be included in the xml file later.