Checklist to File ACA Application for TCC

Affordable Care Act (ACA) required reporting is right around the corner. In order to e-file ACA information returns with the IRS, you need to obtain a Transmitter Control Code (TCC). Gather and check off the items you need to complete required fields on the ACA Application for TCC.

The checklist below is based on the new version of an IRS tutorial and expands on step 3 in my post on the ACA Information Returns (AIR) system. But first, let me provide some background information.

Checklist to File ACA Application for TCC

What is the purpose of a TCC?

E-filing is required for providers of minimum essential coverage that file 250 or more information returns during the calendar year. The purpose of the TCC application is to receive a TCC to become authorized to e-file Forms 1094B, 1095-B, 1094-C and 1095-C.

Does your organization need to designate Responsible Officials?

If your organization performs any of the following roles, you must designate Responsible Officials to complete the application.

  • Issuer: An organization that files its own ACA information returns
  • Transmitter: A third party that sends electronic information return data directly to the IRS on behalf of any business
  • Software Developer: An organization that writes origination or transmission software according to IRS specifications. (The software developer role and duties are outside the scope of this blog.)

The roles are not mutually exclusive.

What is the application process?

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Identify the Responsible Officials and Contacts. All Responsible Officials and Contacts need to be registered and confirmed with IRS e-Services before the application can be submitted. Each Responsible Official (minimum of two required) and Contact (minimum of two required) within the organization must complete the e-Services “Secure Access Authentication” process before the application can be submitted. Responsible Officials may also be Contacts on the application.

Access the TCC application in IRS e-Services and start filling it out. All Responsible Officials must sign the Application Submission Page with their e-Services PIN to submit the application. Note: Responsible Officials may go to the Modify PIN tab to recover their e-Services PIN.

After the application is submitted and processed, the IRS will assign a TCC for each role selected on the application. TCCs are sent to you via U.S. Postal Service and appear on the summary screen of your completed, processed application. The typical application will be processed within seven business days.

Who should apply for a TCC?

Section 2 of IRS Publication 5165 explains who should apply for TCC, emphasizing, “If you are an employer or insurance issuer/carrier using a 3rd party to prepare and transmit your information returns to the IRS, you do not need to obtain a TCC.”

Confused about the TCC roles? IRS Publication 5165 includes a table titled “What roles should I select on my ACA Application for Transmitter Control Code?” containing if-then scenarios. See Table 2-1 on page 11 as of March 2019.

Checklist of information required to apply for TCC

Firm information

  • Employer identification number (EIN)
  • Legal name
  • Doing-business-as name (if different than legal name)
  • Business type (select from a drop-down list)
  • Phone number
  • Mailing address (PO Box is acceptable)
  • Business address if different from mailing address (PO Box is not acceptable)

Responsible Officials information

Note: A Responsible Official can also be a Contact. You are required to enter at least two Responsible Officials.

  • Name
  • Position or title (select from a drop-down list)
  • U.S. citizen
  • Social Security number or individual tax ID number
  • Date of birth
  • E-mail address
  • Phone number
  • Determine if this person will also be a Contact

Contacts information

Note: Contacts should be available on a daily basis to answer IRS questions. You are required to enter at least two people.

  • Name
  • Position or title (fillable field)
  • U.S. citizen
  • Social Security number or individual tax ID number
  • Date of birth
  • E-mail address
  • Phone number

Other details requested in application

  • Role(s) performed by your organization
    • Issuer Role(s) performed by your organization
    • Transmitter
    • Software Developer
  • Form(s) you will be submitting
    • 1094/1095-B Health Insurance Coverage and transmittal
    • 1094/1095-C Employer-Provided Health Insurance Offer and Coverage and transmittal
    • 8809 Application for Extension of Time to File Information Returns
  • Transmission method for each of the forms you will be submitting
    Note: The electronic format of ACA information returns is Extensible Markup Language (XML), a language that specifies the structure and content of electronic documents and files.
    • ISS-A2A System Enroller: This option involves a machine-to-machine process to send a Simple Object Access Protocol (SOAP) message. The information return data is sent in XML structured data files as an attachment to the SOAP message.
    • ISS-UI for ACA Internet Transmitter: This option involves using an internet browser to browse for and upload the respective information return as an XML file.

PIN to e-sign terms of agreement for each Responsible Official.

[Related E-Learning Course: Overview of ACA]

To learn more, visit our ACA University web page on reporting and disclosure. For more specific information on transmission methods and files, see section five of IRS Publication 5165, Guide for Filing Affordable Care Act (ACA) Information Returns for Software Developers and Transmitters, as well as the AIR Submission Composition and Reference Guide.

Jenny Lucey, CEBS

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

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Comments (20)

  1. AvatarNatasha Peterson

    Do you have a little more detail on the two different transmission methods for reporting? How do we know which method we should choose when registering for the TCC?

    Reply
    1. Jenny LuceyJenny Lucey

      You can find more detail in Publication 5165, Section 5, Transmission Methods for AIR, available at http://www.irs.gov/pub/irs-pdf/p5165.pdf.

      Reply
  2. AvatarMichael Schwadron

    The IRS is requiring our *personal* AGI as part of the registration process. It’s not in your checklist.

    Reply
    1. Ann Godsell, CEBSAnn Godsell, CEBS

      You are correct, Michael! That detail is included in our previous post “Four Steps Required Prior to ACA E-Filing”. (See step 2: http://blog.ifebp.org/index.php/four-steps-required-prior-to-aca-e-filing.)

      Reply
  3. AvatarPriscilla

    For the different types of TCC are there certain entities that may need multiple codes? For example if you are an ALE transmitting on your own behalf but also transmitting on behalf of other groups as their TPA? In this case would you transmit as an issuer for yourself and transmitter to transmit for others or would simply registering as a transmitter suffice both? Thanks!

    Reply
  4. AvatarChad Stutzman

    Is the TCC different than the code required to file W-2/W-3’s electronically? Thank you!

    Reply
  5. Jenny LuceyJenny Lucey

    Yes, the ACA TCC is different. Forms W-2/W-3 are electronically filed with the Social Security Administration through SSA’s Business Services Online (BSO). You can find more about BSO at https://www.ssa.gov/employer/. BSO is separate from the AIR system.

    Reply
  6. AvatarJeannie

    We have multiple companies but would fall under the Large Employer Member (ALE Memeber) when transmitting the 1094-C. On this form I see we can list all ALE Member information with their EIN numbers since they are part of the Aggregated ALE Group but do I need to apply for separate TCC numbers for each of our companies?

    Reply
  7. AvatarLori

    Can we print and Mail the 1095-c to employees before transmitting the 1094-c to the IRS

    Reply
  8. AvatarVishnu Dawah

    There are three defined roles to apply for a TCC – Responsible Official, Contact and Software Developer. On all of the documentation I have found it is required that there be at least one Responsible Official and two Contacts, but no where can I find that a Software Developer is mandatory.

    Is a Software Developer mandatory to obtain a TCC?

    Thank you.

    Reply
    1. Jenny LuceyJenny Lucey

      No, selecting the Software Developer role is not mandatory. In the “Application Details” section of the TCC application you have to select at least one role and you can select more than one. You can select any combination of roles. Each role selected on the application results in a separate TCC.

      Reply
  9. AvatarElizabeth Hughes

    I have completed the registration to e-services and I’ve seen the tutorial on filing for the TCC, but I must be missing something because I cannot literally find the TCC application to begin.

    Reply
    1. Jenny LuceyJenny Lucey

      The TCC application is on the website for IRS e-services, available here https://www.irs.gov/Tax-Professionals/e-services—Online-Tools-for-Tax-Professionals. On the left side of the page under e-services, click “Login or Register”. Log in using your username and password. Select Application from the menu and select ACA Application for TCC to begin.

      Reply
  10. AvatarTanya

    I applied to be both an issuer(for our company) and transmitter (for 4 of our subsidiaries). I received two separate TCC codes. However, none of the subsidiary names are listed anywhere (I was not asked to provided during the application process) and so now I don’t know how to add them so I can start submitting for them. TIA!

    Reply
    1. AvatarTracy

      Were you able to get this answered? I’m having the same problem. thanks!

      Reply
      1. JennyJenny

        I noticed a similar, but not exact, Q&A was addressed in the ACA AIR Working Group Meeting on June 14, 2016.

        “Question #9: Does each Applicable Large Employer (ALE) member of an Aggregated ALE group need to have their own TCC code (each ALE member having their own EIN) for electronic submission? IRS Response #9: TCCs are assigned by EIN. If each ALE group is going to transmit their own return, then each group will need their own TCC code.”

        See Technical Question #9 on slide 51.
        https://www.irs.gov/pub/info_return/June_2016_Webinar_Presentation.pdf

        Reply
  11. AvatarLynne

    How do I add a contact after I already applied and received my TCC Code?

    Reply
  12. AvatarJulie

    My application says “submitted pending review”, Am I waiting on the IRS to review? I’m unclear.

    Reply
  13. Avatarannie cheng

    How long does it take for the tcc application to go through? The application is completed and now I’m just waiting. Also, will the code show up via email or via the sign in page?

    Reply
    1. AvatarPaige Martin

      How long did it take for your TCC application to get processed and how did you receive the TCC Code? Did it show up on the site or come via email?

      Reply

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