Affordable Care Act Services
While many businesses may be thinking that the Affordable Care Act (ACA) will be changing or be repealed soon due to the new Federal administrating coming into the White House on January 20th, the fact remains that as of today, the ACA is still in effect, which means that employers - particularly Applicable Large Employers (ALEs) - will be required to file IRS Forms 1094 and 1095 in early 2017 for the 2016 filing year, under IRS Code Sections 6055 and 6056.
However, certain relief has been provided by the IRS. On November 18, 2016, via IRS Notice 2016-70, the IRS extended the 2017 due date for providing 2016 health coverage information forms to individuals. Insurers, self-insuring employers, other coverage providers and ALEs now have until March 2, 2017 to provide Forms 1095-B or 1095-C to individuals/employees, which is a 30-day extension from the original due date of January 31, 2017.
Notice 2016-70 also extends transition relief from certain penalties (IRC Sections 6721 and 6722) to providers and employers that can show that they have made good-faith efforts to comply with the information-reporting requirements for 2016 for incorrect or incomplete information reported on the return or statement. This Notice also provides guidance to individuals who, as a result of these extensions, might not receive a Form 1095-B or Form 1095-C by the time they file their 2016 tax returns. It is also abating penalties for inadvertent errors and omissions where there was a good-faith effort to comply with the reporting requirements.
The due dates for filing 2016 information returns with the IRS remain unchanged for 2017. The 2017 due dates are February 28 for paper filers and March 31 for electronic filers.
Tronconi Segarra & Associates offers ALEs an electronic e-filing solution to report that information to the IRS so as to avoid any potential IRS penalties that may be imposed on an ALE for lack of or late reporting.
Tronconi Segarra & Associates is offering this compliance service on a per-form fee basis to ALEs. Unlike others offering this compliance service, Tronconi Segarra & Associates’ service offering is neither contingent on having an existing relationship with our Firm, nor on establishing a future relationship with our Firm. We are accepting these compliance engagements on a stand-alone basis. All ALEs for whom we provide this e-filing compliance service will be asked to sign an engagement letter which will include our cost for the service, based on the ALE’s number of full-time employees (and therefore, the number of Form 1095s that must be prepared), as well as Form 1094 that is e-filed with the IRS.
Tronconi Segarra & Associates realizes that some employers may not know whether they qualify as an ALE, and therefore whether they are subject to the IRS Form 1094/1095 filing requirement.
Tronconi Segarra & Associates offers ACA consulting services (at fees separate from the compliance services fees described above, and varying depending on the nature of the service and the Tronconi Segarra & Associates associate providing the service.) Such consulting services include, but are not limited to:
- Headcount tracking & determination of status as an ALE.
- Calculations of full-time-equivalents; analysis of seasonal and variable-hour employees.
- Testing of health insurance affordability.
- Tax implications of Individual/Employer Mandates & Employer Shared Responsibility Provision.
- Assistance with small employer health care provisions, including the small business health care tax credit.
- Tax filing associated with the Patient-Centered Outcomes Research Institute Fee (PCORI).