Our ACA compliance team regularly attends IRS webinars for the Affordable Care Act Information Returns (AIR) Program, the program that will be used to provide required reporting to the IRS for 1094 and 1095 data. In this week’s IRS webinar, it was confirmed that employers/transmitters will be allowed to use two transmission methods for sending their data to the IRS.* Here's what you need to know:
- Transmitters will be able to visit a website and manually upload XML files securely to the IRS over HTTPS (UI channel). Keep in mind that even with this option, transmitters must still be approved by the IRS for transmission of files and meet strict acceptance criteria prior to live file transmission.
- For transmitters with the need to exchange high volumes of 6055/6056 data, the IRS is providing a secure SOAP based web service (A2A channel) with MTOM (Message Transmission Optimization Mechanism).
The newest clarification is the requirement to transmit Information Returns along with SOAP messages as MTOM-encoded attachments. If you are anything like me, you might be asking yourself, “What is MTOM?” MTOM is a standard that provides a method of efficiently sending binary data via web services.
As you can see, the transmittal of data to the IRS is very intricate. Technical requirements for transmittal files and APIs have been ever-changing as the IRS revises and clarifies items on a month-to-month basis. Be sure you are taking action to ensure your institution will be ready for the filing requirements.
1094 and 1095 Forms
In addition to the details discussed previously, new drafts of the 1094 and 1095 forms have been made available by the IRS and can be found on the IRS website by searching 1094 or 1095.
Full instructions are still outstanding, but there are some changes for the 2015 year that will be important for you to note on the 1095-C form:
- Increased area for "covered" individuals
- New line 16 codes that will indicate if an employee's offer to the spouse is a conditional offer (more information to come from the IRS)
- New field for "Plan Start Month" - These are optional for 2015 but required for filing years 2016 and later.
Bottom line: We are ready to help our clients with the daunting task of staying compliant amidst the ACA chaos and invite you to learn more about the power of our single source ACA Compliance Suite℠.
*Data received from the IRS Affordable Care Act (ACA) Information Returns (AIR) working group meeting June 23, 2015.
