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IRS Releases Guidance on Voluntary 2015 PPACA Information Reporting

September 1, 2015

As discussed in our February 2015 client alert "IRS Releases Additional Guidance on Reporting Health Coverage Information", employers subject to the health coverage information reporting requirements of the Patient Protection and Affordable Care Act of 2010, as amended ("PPACA"), have the option of filing the applicable returns (IRS Forms 1094 and 1095) on a voluntary basis in late 2015.  The IRS has recently finalized two publications addressing the electronic filing process.  Even employers who do not choose to make voluntary submissions this year will want to familiarize themselves with the process summarized in this client alert which is unlikely to change substantially for the required submissions beginning in early 2016

Whether an employer first files Forms 1094 and 1095 in 2015 or 2016, the electronic filing process will take place in two stages:  test filing and actual filing.  Prior to either, one or more Responsible Officials and at least two Contacts must be designated for communications with the IRS.  Only certain senior officials within an organization may be designated as Responsible Officials who then register for electronic services and apply for a Transmitter Control Code ("TCC") which serves as a unique identifier for the organization. 

Test filing takes place through the Affordable Care Act Assurance Testing System ("AATS").  In order to be accepted, hypothetical taxpayer data provided by the IRS in one or more "scenarios" consisting of a single Form 1094 and accompanying Form(s) 1095 must be transmitted without error to the IRS.  IRS Publication 5164 provides detailed information about these testing procedures.

Actual filing takes place through the Affordable Care Act Information Returns ("AIR") Program using the TCC as described above.  The required data exchange between the employer and the IRS involves numerous technical protocols concerning transmission methodology, composition, and data structure.   IRS Publication 5165 provides detailed information about these protocols, together with the processes for validation, correction, and replacement.

The AATS and the AIR Program represent the technical implementation of the PPACA information reporting regulations we discussed in our March 2014 client alert "Final IRS Regulations on Information Reporting under PPACA".   For more information about reporting under PPACA, PPACA compliance in general, or other issues concerning your employee benefit plans, please contact Joanne C. Youn at jyoun@capdale.com / 202.862.7855.

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About Caplin & Drysdale
Having celebrated our 50th Anniversary in 2014, Caplin & Drysdale continues to be a leading provider of tax, tax controversy, and litigation legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills - combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment - make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:

-Bankruptcy
-Complex Litigation
-Corporate Law
-Corporate, Business & Transactional Tax
-Employee Benefits
-Exempt Organizations

-International Tax
-Political Law
-Private Client
-Tax Controversies
-Tax Litigation
-White Collar Defense

 

For more information, please visit us at www.caplindrysdale.com.

Washington, DC Office: 
One Thomas Circle, NW
Suite 1100
Washington, DC 20005
202.862.5000

       

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21
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New York, NY 10022
212.379.6000

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Disclaimer
This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

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It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.

© 2015 Caplin & Drysdale, Chartered
All Rights Reserved.

________________________________________________

About Caplin & Drysdale
Having celebrated our 50th Anniversary in 2014, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at www.caplindrysdale.com.
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
202.862.5000
New York, NY Office:
600 Lexington Avenue
21st Floor
New York, NY 10022
212.379.6000

___________________________

Disclaimer
This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
© 2019 Caplin & Drysdale, Chartered
All Rights Reserved.

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