IRS AIR Corrections are Front and Center

IRS AIR Program ERROR late filing and correction of data e-filing etc.  is not as straightforward as one would assume.  The following information has been prepared to help you understand what to do about Corrections. You can download the information here.Information on Corrections in Knowledgebase Ver .95.pdf

Latest IRS guidance on Penalties

Filers that miss the June 30, 2016 due date will not generally be assessed late filing penalties under section 6721 if the reporting entity has made legitimate efforts to register with the AIR system and to file its information returns, and it continues to make such efforts and completes the process as soon as possible."   Read the actual Quick Alert here: https://www.benefitscape.com/Portals/1/Documents/Late%20Filing%20Suggested.pdf

 There is also a 46 minute Video, with a transcript, provided by the IRS.

http://www.irsvideos.gov/Governments/AffordableCareAct/AffordableCareActInformationReturnsCorrectionsProcess

 here are charts on pages 4-5 of the instructions for Forms 1094-C and 1095-C https://www.irs.gov/instructions/i109495c/ar01.htmland page 5 of the instructions for Forms 1094-B and 1095-B, that list examples of errors that need to be corrected and how to correct them. Below are the instructions for Form 1095C.


Original Form 1095-C Submitted to IRS and Furnished to Employee

IFany of the following are incorrect ....

THEN...

 

 

1. Name, SSN, Employer EIN

2. Offer of Coverage

3. Premium Amount

4. Safe Harbor and Other Relief Codes

5. Covered Individuals Information

1. Prepare a new Form 1095-C

2. Enter an “X” in the “CORRECTED” box at the top of the form

3. Submit corrected Form 1095-Cs with a non-authoritative Form 1094-C transmittal to the IRS

4. Furnish a corrected Form 1095-C to the employee

 

 

 

 

Third Party E-filer makes getting your own TCC unnecessary!

The IRS AIR System enables Third Party E-filers...So there is no need to go through the IRS AIR Application and Testing Process to become a software developer, transmitter, or issuer (company) that is filing your own returns! 

The IRS points out that "if you are an issuer using a third party and you are not transmitting information returns directly to the IRS, you should not apply for a TCC."  This should come as quite a relief to many companies that had difficulty getting their own Transmitter Control Code (TCC).

As a Transmitter, having sent thousands of XML files to the IRS AIR; we are prepared to help you today.



How the BenefitScape VAN transmits to the IRS AIR System

You have prepared the Form 1095's and now you need to send this data to the IRS.

No matter what the format of your Form 1095 information, the BenefitScape VAN can load, translate and transmit for you!

BenefitScape VAN

Affordable Care Act Information Returns (AIR) Program requires an XML format for electronic submission.

BenefitScape has been working on HRXML solutions for years and is prepared for this challenge, offering a cloud-based Value-Added Network (VAN): a software based service that acts as an intermediary between our clients and the new IRS AIR platform.

Employers have been using VANs for complex data transmission, like ANSI 834, in the Healthcare arena for decades.

Now, a VAN is available for IRS ACA e-Filing.

How to Manage Air Corrections

 

You may not be able to check that  BOX…just yet!

Now that the 1095 Forms are in employee hands the inevitable corrections are appearing.  It may be tempting to check the “Corrected Box” but don’t do it!..unless you have already filed the 1095 report with the IRS.   Instead enter “ CORRECTED” on the form and redistribute it..  The IRS instructions are  Enter an “X” in the corrected checkbox only when correcting a Form 1095-C previously filed with the IRS. If you are correcting a Form 1095-C that was previously furnished to a recipient, but not filed with the IRS, write CORRECTED on the new Form 1095-C furnished to the recipient.”

Its not over until its over   Also don’t forget that e-filing to the new AIR System is not a one and done process. It can be ongoing, which complicates the correction process, since all forms may not be filed at once.  



AIR Business Rules include robust TIN/SSN matching

Error Code AIRTN500 – TIN Validation Failed. 
•     This means an Individual Name and Social Security Number does not match 
IRS database. The Error Data File will only identify the “UniqueRecordID in 
the submission that has a TIN Validation Error and not the specific Name or 
SSN of the Individual that caused the error. 


TCC Numbers and AATS Software Testing

The IRS will only accept electronic forms in Extensible Markup Language (XML) format. XML format is a markup language that defines a set of rules for encoding documents in a format which is both human-readable and machine-readable. Portable Document Format (PDF), Microsoft Word, Microsoft Excel or any other electronic format will not be accepted. Complete details are available at the  IRS AIR OFFICIAL WEBPAGE...

Credentials and extensive testing are required to submit an e-filing for ACAGenerally, any entity that submits electronic returns through the AIR Program will have to:

  1.  Complete the e-Services Registration to obtain log-in credentials. 
  2. Complete the ACA Information Return Transmitter Control Code (TCC) Application  The IRS has issued a tutorial for requesting a TCC. The TCC Application is obtained through e-Services.   
  3. Next, you must comply with the requirements of the Affordable Care Act Assurance Testing System (AATS)  to insure that you can provide communicate, provide the correct data. Only then can you begin your e-filing. Details are in the AIR Submission Composition and Reference Guide.


The Dilemma faced by Employers who have produced their Forms 1095

In a word: "e-Filing".  While preparing the Form 1095-B/-C is complex, e-filing to IRS AIR is straightforward but it requires significant technical skills that most employers do not have.  This where our VAN comes into play.  Why remake the wheel for a one time annual filing?  Let us handle the data and e-filing for you!



Do not forget 'TIN VALIDATION" errors IRS AIR

First, the regulations and guidance are not crystal clear on how errors need to be corrected to avoid potential penalties? What is clear is that Penalty relief is provided if you did not file or furnish accurate returns but you can show you made a good-faith effort to comply with the requirements. Correcting errors is part of the good-faith effort to file accurate and complete information returns. Consequently, it needs to be done.

What causes TIN Validation Error AIRTN500?

One of the most common ACA e-filing errors that is returned from the IRS AIR system is TIN Validation Error AIRTN500.

This typically happens when the last name and SSN don’t match what the IRS has on file. This can happen for the following reasons:

• Maiden name used when married name is registered with the SSA (or vice-versa)
• Often times it is the result of a Last Name used where 2 last names are common. The first last name listed must be the one registered with the SSA.



AATS Testing Scenario-XML Sample

If you are attempting IRS AATS, the testing Scenarios provided by the IRS are very detailed and straightforward.  Combined with the XML Schema, they provide all a technician needs to prepare the submissions successfully.  It also helps to have a pattern to follow. We are pleased to provide an XML sample for you; all it requires is that you Register with us to receive the download.  Your info is secure and we never sell or provide it to anyone. Contact Us  to make your request.



Using the IRS AIR e-Filing System

To receive a waiver, reporting entities must submit Form 8508, Request for Waiver From Filing Information Returns Electronically, at least 45 days before the due date of the returns.  Important Note:  The Form requires attaching 2 Cost Estimates

Enter two current cost estimates provided to you by third parties for software, software upgrades or programming for your current system, or costs to prepare your files for you. Cost estimates for any reason other than the preparation of electronic files will not be acceptable. Attach the two current cost estimates to Form 8508. Note: Failure to provide current cost estimates and/or signature will result in a denial of your waiver request. 

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IRS Clarifies AATS Phase 2 Availability Dates

The Internal Revenue Service (IRS) announced that starting January 19, 2016 a more complex environment for the Affordable Care Act Assurance Testing System (AATS) called Phase 2 AATS will be available. The testing environment will provide additional improved error messages for business rule execution errors. 

  • Phase 1 AATS will be shut down at Midnight Eastern on January 15, 2016.
  • Phase 2 AATS will start on January 19, 2016.Phase II is testing under the robust environment, which mirrors Production

Phase 2 AATS requires the use the  5164 Publications, Test Package for Electronic Filers of Affordable Care Act Information Returns (AIR). Publication 5164 

BenefitScape has completed all of the testing required and is providing an XML Sample for Scenario 1 (Form 1095-B, minus our specific credentials) for your examination.