The IRS’ latest moves serve as a critical reminder to employers everywhere that ACA reporting season will be here before they know it.
First, the agency released the final Forms 1094-B and 1095-B and the related instructions.
‘C Forms’ right behind
These “B Forms” are filed by minimum essential coverage providers, which are mostly insurers and government-sponsored programs but also some self-insured employers.
Even if you’re not a self-insured plan, you’ll want to pay attention.
Reason: The release of these final forms mean the final Forms 1094-C and 1095-C (the forms most employers fill out) will be released any day now.
As most HR pros know, the agency recently released draft versions of Form 1094-C and Form 1095-C for the 2016 ACA reporting year as well as draft instructions.
And the IRS did alter some aspects of the forms for next year’s reporting.
One prime example:
- Form 1095-C, Part II, Line 14: Codes 1J and 1K have been added. The two new codes will indicate conditional offers of healthcare to spouses.
In addition to the final forms, the IRS announced changes to the identity authentication process for e-Services, which includes tools used in connection with the electronic filing through the Affordable Care Act Information Returns (AIR) Program system.
According to the feds, the changes will strengthen protections for e-Services accounts by requiring two-factor authentication to use the feds’ Secure Access platform.
If you are one of the employers that must file electronically for the first time, there are four key steps to prior prior to e-filing and can start doing now, according to the International Foundation of Employee Benefit Plans’ (IFEBP) Word on Benefits blog:
1. Name your responsible official/officials and contacts. The responsible official — or officials — has the authority over the e-filing process for the company at one location, and he or she is also the contact person for communication with the IRS. The contacts are the folks who may be transmitting the e-file returns as well as those may answer questions from the feds on a daily basis. All companies must put at least one responsible official and two contacts on their applications.
2. Register your official/officials and contacts with IRS e-services. The feds need to authenticate the officials and contacts your firm named on its application so you can do business with the IRS electronically. Your company’s responsible officials and contacts will need to enter personal info such as social security number and adjusted gross income. Once this process is complete, the feds will mail out a registration confirmation code. After the code is received, officials and contacts must log in to the IRS’ e-services and enter the confirmation code to complete the registration.
3. Apply for the code. Anyone transmitting info to the IRS is required to complete an ACA Information Return Transmitter Control Code (TCC) Application online through e-services. Then, they’ll receive a TCC in the mail. The IRS also has a tutorial on the application process on its website.
(Note: Health insurance issuers or carriers only need a TCC if they are acting as the transmitter.)
4. Test. After receiving the code, transmitters must complete an error-free communication test. In order to pass, the transmitter needs to do the following:
- prepare a transmission in XML format
- submit that transmission for processing
- receive a receipt ID, and
- obtain the acknowledgment and attached error file (if applicable).