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ACA_complexBusinessolver strongly believes that part of our mission as a benefits technology partner is to help our clients navigate the changing legislative environment. That mission includes helping our clients understand and respond to the often confusing ACA reporting requirements, which is why we regularly attend IRS webinars for the Affordable Care Act Information Returns (AIR) Program, the program that will be used to provide the required reporting to the IRS for the 1094 and 1095 data. The webinars are a great way to get the latest information straight from the source on the latest ACA reporting requirements.

Last week we had another great session of information gathering while sitting through the latest IRS AIR Standards webinar. We’ll spare you the fun of listening to the last few webinars yourself and highlight a few key takeaways that you might find helpful:

  • The Transmitter Control Code (TCC) limit of 1,100 transmissions per code has been lifted. You can expect formal written notice from the IRS very soon.
  • The testing site for 2015 returns is not expected to be available until November. That doesn't leave much time for every company needing to transmit data or apply for a Software ID approval to test for the March 2016 electronic filing deadline, so be sure you are prepared!
  • There is a new 1095-C form for 2015 that will include additional lines for "Covered Individuals".
  • Confirmed on this week's call - if a member is "covered" for even one day during the month they are able to be marked as "covered" for that month on the 1095-C document.
  • You are allowed to modify the IRS 1095 reporting documents—the only requirement is that your modifications must include the same data as the model forms.
  • No signature is required for 1094 documents filed electronically, only if they are paper documents (and remember, paper documents are only allowed to be filed with the IRS if your filing has less than 250 employee 1095 forms attached).
  • Employers with multiple 1094-C documents will only complete the entire form for the Authoritative filing document. Additional filings will only need to include Part I.

These regulations might seem cumbersome and difficult (because they are!), but know that we understand the ACA challenge employers are facing and are here to help you. Our goal is to support employers with innovative technology that is both flexible and nimble to respond to changing legislation, especially when it comes to ACA compliance. If you don't yet have a solution, let's talk--it's not too late! And if you missed our last webinar, "ACA--Containing the Chaos", that goes over current status of ACA and its continued impact on employers regarding reporting, compliance and penalties, we encourage you to listen to it on demand.

 

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