As Details Are Clarified for ACA Reporting, Uncertainties Prompt Requests for Flexibility

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Reporting requirements under the Affordable Care Act are to take effect in early 2016 but because many employers still are dealing with IRS compliance requirements, some are seeking more time to file that surpasses extensions already granted, companies and business groups said.

The two main issues facing employers are the need for more clarity in the procedures for filling out ACA Form 1095-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return, and how minimum essential coverage is reported when an individual is covered through two or more plans offering such coverage at the same time.

Employers filing at least 250 Forms 1095-C with the Internal Revenue Service are required to use the electronic ACA Information Returns (AIR) program, said Benjamin Lupin, senior regulatory adviser for health and group benefits at Towers Watson & Co. in Philadelphia.

Form-Filing Process Adds Separate Registration Requirement

Lupin, speaking Nov. 18 at an American Payroll Association chapter meeting in Richmond, Va., said those electronically filing ACA forms should identify a responsible official and contacts, separately register apart from other form-filing systems with IRS e-services for AIR and apply for a transmitter control code. Employers and information technology departments should work together to test the system, he said.

The IRS made the AIR system available to employers Nov. 2 for testing the 2015 forms, the agency said Nov. 18 in a web presentation.

In Part 2 of Form 1095-C, employers are required to use numerous codes that are dependent on the coverage made available and the employee status of each individual, Lupin said.

For an employee who was offered coverage during the annual enrollment period and elected coverage for the full 12 months of the year, employers are to put code 1E on line 14 of Part 2 in the column “All 12 Months” and 2C on line 16 in the same column. On Line 15 of the same column, employers are to enter the amount, including cents, of the employee share of the lowest-cost monthly premium for self-only minimum essential coverage providing minimum value that is offered to the employee. No other entries in Part 2 would be required, Lupin said.

Other scenarios Lupin presented require filling in the monthly columns using a mix of the codes provided. The process is further complicated by the requirements on the transmittal forms, he said.

Separately, the National Payroll Reporting Consortium asked the IRS on Nov. 18 for the ability to use either IRS or Social Security Administration systems to verify tax identification numbers and names reported on ACA forms. The American Benefits Council asked the IRS to adopt “the broadest possible rule” so as to limit the need to report supplemental health coverage, while the National Business Group on Health asked the agency to allow providers to only report minimum essential coverage enrollment one time if they provide multiple plans covering the same individual.

To contact the reporter on this story: Michael Baer in Washington at

To contact the editor responsible for this story: Michael Trimarchi at


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