Here is a short check list to help prepare for the 1095-C reporting:
- Read and understand the instructions from the IRS. Make sure you understand what relief your company may be eligible for and how this is reported on the forms. Datatech cannot advise you in this area.
- File for an extension (Form 8809). There is more information in the instructions. Although we don’t expect it to be needed, it doesn’t hurt. If something beyond our control occurs, the extension will provide an additional 30 days to file your 1094-C/1095-C’s with the IRS.
- Make sure that all offers of coverage have been entered into your system. This includes all offers that employees accept as well as offers that were declined. The Compile 1095-C program option will combine information from the payroll system with the information on the plans you offer and the offers made to employees to determine what codes will be put in the line 14/15/16 boxes.
- Check with your insurance company to see if they will be able to provide a file after the end of the year listing all employees that were enrolled and the months in which they were enrolled. For employers that have self-funded plans, this information will be reported in Part III of the 1095-C. If your insurance company cannot provide you with this type of file and you want to check the information in the HR system against the insurance companies information, it may be necessary to compare detail bills from the insurance company against the HR’s list of employees that were enrolled for each month.
- There may be situations where the codes reported on the 1095-C are ambiguous or open to interpretation. The IRS has not provided any examples of how the 1095-C is to be filled out in different scenarios. Nor have they provided an equivalent to Publication 15 for employers to follow for ACA compliance/reporting.We will do our best to clearly explain the logic used by the program in determining the codes that are reported based on our understanding of the instructions. If you have questions about a particular scenario, we will likely not be able to provide advise on how to handle a particular situation. We may be able to submit a question to the IRS, but they may choose not to answer. The IRS has refused to answer several of our questions about the correct codes to use in different scenarios.
An update the HR program should be available in the next few days with revisions to the Compile 1095-C option. We will post another article when this version is released detailing the changes.