Affordable Care Act (ACA) electronic information returns are due to the IRS by April 1, 2019. You’re already collecting health coverage reporting details, so it’s time to get ready for ACA e-filing.

What are ACA Information Returns?

To support ACA provisions for individual shared responsibility and employer shared responsibility that were effective January 1, 2015, the IRS will receive and process information returns reporting on individual health insurance coverage from:

• Providers of minimum essential coverage (MEC) (e.g., health insurer, sponsor of a self-insured health plan, government agency that administers government-sponsored health insurance programs) using Forms 1094/1095-B
• Applicable large employers (ALE) using Forms 1094/1095-C.

What is AIR?

Affordable Care Act Information Returns (Forms 1094-B, 1095-B, 1094-C and 1095-C) must be filed using the Affordable Care Act Information Return (AIR) system. The AIR system is specifically designed for the IRS to process ACA forms. Other IRS e-filing systems do not support the ACA information returns.

Who must e-file?

Providers of MEC that file 250 or more information returns during the calendar year must file the returns electronically. For a provider with fewer than 250 returns, electronic filing is voluntary. However, the IRS encourages all entities to file returns electronically.

Who are issuers and transmitters?

The AIR system uses the term “issuer” to refer to any provider of minimum essential coverage. “Transmitter” refers to a third party that files information returns on behalf of an issuer that is required to file returns.

Note for Issuers: It’s time to determine if you have a third-party transmitter or if you will act as your own transmitter by e-filing your returns directly with the IRS.

When is reporting due?

For calendar year 2018, electronic filing is due April 1, 2019.

Four steps prior to ACA e-filing:

1. Identify your Responsible Officials and Contacts.
   The Responsible Official has authority over the electronic filing of ACA information returns for the organization at one location and also is the first point of contact with IRS. Contacts are individuals who may be responsible for transmitting and/or are available for inquiries from IRS on a daily basis. At least two Responsible Officials and two Contacts must be provided on the application.
2. Register with IRS e-Services.
   All Responsible Officials and Contacts need to be authenticated by the IRS. Registration is an authentication of you as an individual that allows you, representing yourself or your company, to do business with the IRS electronically. The IRS changed the registration process in November 2018. Be ready for an identity proofing process, “Secure Access,” which includes questions to confirm your email, tax return information, financial account information and mobile phone confirmation. Here’s a checklist of what you need to have handy before you get started.
   • Note: If you’ve previously registered with IRS e-Services, you need to re-register for a Secure Access account for e-Services. Here’s an overview of the steps:
     • Log in with an existing e-services username and password
     • Submit financial account information for verification, for example, the last eight digits of a credit card number or car loan number or home mortgage account number
     • Submit a mobile phone number to receive an activation code via text OR request an activation code by mail.
3. Apply for TCC
   Transmitters need to complete the ACA Information Return Transmitter Control Code (TCC) Application online through e-Services and receive a TCC in the mail. TCCs are also available to be viewed on the summary screen of the applicant’s online application. Issuers only need a TCC if they are acting as a transmitter. The IRS posted a tutorial on the application process. Here’s a checklist of what you need to have handy before you get started.
4. Participate in testing.
   Transmitters need to complete an error-free communication test. To pass a communication test, the transmitter must prepare a transmission in XML format, submit it for processing, receive a receipt ID, and obtain the acknowledgment and attached error file if applicable. For more specific information on testing, see IRS Publication 5164.

After completing these four steps, you’re set to e-file ACA Information Returns.

Keep up with ACA’s latest transformations on ACA University, a free member service offering the latest news and insights you need to know about. 

Jenny Lucey, CEBS
Manager, Reference/Research Services at the International Foundation