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Tuesday, February 2, 2016

photo77Well, we’ve toyed with your emotions enough on this subject…. the deadlines for ACA reporting have not changed. Truth be told, unless this law is repealed by a Republican President taking office next term, we’re likely stuck with the ACA reporting rules as they stand (as modified by further informal guidance). So, what if you encounter this situation under the current legal landscape? You’ve made it through information compilation and data entry processes, you’ve poured over the instructions on the Forms 1094 and 1095s (or better yet, hired a consultant to do that) and you’re now ready to submit your returns electronically to the IRS – maybe even “on time” under the initial deadlines before they were extended. Congratulations! But, what happens when you receive a dreaded “error” message in connection with that submission?

First and foremost, please stay calm!

We know you’re at your wits end with this whole endeavor, but that IRS is actually poised to help (we hope). Last week, the IRS held a webinar concerning how to deal with rejection. And while they cannot help you with rejection in the dating world (sorry us ERISA nerds are left to search the galaxy for someone who loves us for who we are and our “humor”), they may be able to assist with submission rejection errors. Slides from the presentation entitled “Things to Know, Overview of Rejection Triggers, Tax Year 2015 Lessons Learned, Form 1094/5-C Q&A” attempt to answer many questions on various types of errors filers may encounter (including differing types of errors at the Transmission level: (i.e., the entire Transmission is rejected) or Submission level (i.e., one or more but not all of the Submissions in a Transmission are rejected) and how to address these errors.

These slides also address a series of more general Q&As on how to complete the forms. For example, two Q&As state that Line 15 on Form 1095-C (which lists the employee share of lowest cost monthly premium for self-only MV coverage) should be completed if an offer of coverage (other than a qualifying offer for all 12 months of the calendar year) is reported on Line 14 whether or not the employee enrolled in the coverage offered. Stated simply, unless you’re entering Code 1A in the All 12 Months box in Line 14, then something should be listed on Line 15.

This latest publication is just one in a series of presentations hosted by IRS working groups and posted on IRS.gov. If you’re interested in reviewing prior releases, that information can be found here. Less technical and more legal ACA guidance issued by the IRS for applicable large employers is also all posted here.

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