ACA Reporting: TIN Corrections Update

Across the nation, employers have breathed a sigh of relief as June 30th came and went. ACA reporting for 2015 was over and all could go back to normal… Until the TIN errors were presented.

A TIN error is a discrepancy in the employee data that was presented to the IRS in a company’s ACA XML. The discrepancy could be an incorrect social security number. The discrepancy could be the name of an employee is not the same as on their social security card. If you are a self-funded company, the TIN could be a dependent with discrepancies that will need to be corrected.

All of this can be a bit daunting and extremely overwhelming if your company is quite large. Not to mention the error report does not indicate which of the discrepancies has occurred. But rest assure, we are trying all we can to get the most up to date explanations from the IRS to make any corrections needed.

On July 19th, the IRS held a TIN corrections webinar. They were able to clarify a few of the reoccurring questions that we have gotten from our clients. They are as follows:

 

  1. (Q) When is the deadline to make corrections?
    • Within the webinar, the speaker said: “we will be expecting corrections to be made well into 2017”. So there was not a date set that we can give out to clients. However, this does give employers a bit of ease due to the deadline not being around the corner. We would suggest that any corrections be made as soon as you can to give time to start 2016 ACA Reporting!

 

  1. (Q) Do you have any document that we can you to send to our employees that need correction?

 

  1. (Q) When I go to the employee about the corrections, they say all the data is correct. What do I do?
    • This is a very common question we get daily. Due to 2015, being the initial filing, they are allowing employers to use “Good Faith Effort Relief”. The relief is for reporting the most accurate and complete information to the IRS. The down side to the relief, there is not a guideline to what is good faith. Our rule of key is three. If you try to ascertain the corrected information and are unable three times, document the attempts.

 

  1. (Q) I have gotten all my corrections; how do we submit the information to you for filing.
    • We have provided each client with a TIN corrections form. The employee and/or dependent data can be placed within the document. If there are special directions for change, (ie. Taking an employee data out of the filing) you are allowed to write notes in. When completed, you will upload the corrections to your sharefile. If you do not remember your password, please contact support.

 

  1. (Q) Do we need to submit all corrections at one time?
    • Yes. When making corrections to the IRS, you get one try.

The 2015 reporting season was a huge success for us at ACA Reporting Service and for all of our clients. So congratulations all around are in order!

 

 

 

 

 

 

 

 

 

 

Employee Benefit Brokers, ACA Reporting. Huge Prospecting Opportunity, OR Administrative Pitfall?


The Million Dollar Question most employee benefit brokers are considering currently is should our firm try to perform this ACA reporting via an in-house technology solution that we purchase, or recommend having our clients use an outside vendor (such as us here at ACAReportingService.com).  The reality is that every operation is different, has different needs and have promised their clients different things.  Some brokers take a full service approach and look to take administrative burdens off of their clients.  Other brokers take a more consultative approach.  Neither avenue is ‘wrong’, but each works for different type of benefit broker operations.

Regardless of which option you choose, here are some things you should be thinking of as you consider the question:

  • Do we have the necessary resources internally to do a good job with this IRS form filing function?
  • Do we have the knowledge internally to complete the job well?
  • What approach will be most comfortable to our clients?
  • What are the security ramifications of the solution we choose?  (Knowing that having employee social security numbers compromised could be a disaster for your company.)
  • If you decide upon an outsourced solution, will you want to refer your clients to someone who also competes with your company as a benefit broker?
  • Do we need a solution to talk with employers about right now?  What is gained or lost by waiting longer into the year before bringing a good solution to the table?
  • How much time, money and staff will it take to deploy our solution?
  • Would our time be better spent prospecting for new clients during this time using this issue as opposed to trying to manage the process internally?
  • Which option is more profitable to our business?
  • What is the logic of the system we intend to use?  Are the codes and amounts for 1095c lines 14, 15 and 16 automatically generated?  Will our staff or clients be responsible for completing these fields without the assistance of smart technology to intuitively figure out what the codes should be?
  • How will customer service be handled for this whole process?

Often the reality for an employee benefit broker is that a mixture of different solutions makes best sense for their operation.  When it comes to full service ACA 6056 reporting and efiling, we are here to help.  

If you are interested to learn more about things you should be thinking of as a broker, click here for a prior blog post which has proved to be quite helpful.