According to the IRS Notice 2019-63, a year’s extension has been given for good-faith 2019 relief reporting; along with the extension in the deadline for providing employees with ACA information reporting forms, till the 2nd of March.
This is for all those employers who provided their employees with ACA information reporting forms on time; and complied with IRS requirements, but due to some genuine misunderstanding, some mistakes were made in the reporting. In such a case, an employer is usually charged a hefty penalty because of inauthentic or insufficient particulars; but now, they can be relieved of this burden if they can prove their good-faith efforts that were compatible with prerequisites for information reporting - which includes individual furnishing forms and its filing process for the IRS.
Any incorrect or absent birth dates; taxpayer distinguishing numbers and other valid information are also eligible for this relief. However, any forms that weren’t filed with IRS or weren’t provided to the respective individuals won’t be eligible for this relief. Any present employers that are unable to either provide forms to employees or are unable to file information returns (unless if that is provided in the notice) are not eligible for the perks of this relief either.
IRS assured that a strict check would include an analysis of “a coverage provider or an employer’s goodwill attempts in gathering the essential information for reporting” to the IRS; collection of data; employee form furnishing; and the transfer of required data to the representative responsible for IRS data submission.
IRS has rewarded additional relief to those coverage providers for the 2019 reporting year plan whose employees receive 1095-B forms. In the Notice 2019-63, IRS said that coverage providers won’t incur any penalties if they fail to furnish 1095-B forms to their employees if they meet the following criteria:
Additionally, all small employers and insurers are bound to file their 1095-B forms with IRS even if they are not being available for primary insureds as per relief description - says Ed Fensholt, the senior vice president and the director of compliance services at Lockton, a brokerage and consultancy firm.
For applicable large employers, “if the ACA employee did not work for more than a month in 2019, no self-insured employers will be obligated to provide a 1095-C form to them” - to be more precise, Fensholt clarified, those individuals who were not working as full-time employees throughout 2019, ALEs are not obligated to provide 1095-C form to them.
If the self-insured employers wish to be eligible for this relief, they need to meet the criteria mentioned above.
It should be noted that this relief does not extend to full-time employees, and ALEs should follow the same furnishing rules for them as they have been doing in the previous years.
The IRS stated that it will send 1865C form for any ACA reported document which was unable to be smoothly processed for any reasons possible, such as:
These employers will then be granted a time span of 30-days from the date of letter issued to submit the rectified information.
The benefits broker Hub international suggests employers to take the following steps if they use any vendors for ACA reporting in order to avoid receiving 1865C form:
A good practice is to thoroughly go through the forms before they are filed. In fact, your vendor should provide a copy of forms which you can proofread for any possible errors or misprints.
If you didn’t get to check your forms before filing, make sure to go through them once they are filed so that you can spot any potential errors, and if any mistakes are found you can persuade your vendor to re-submit the form in order to avoid the issuance of the 1865C form.
It is important to skim through the forms of prior years to spot errors and coordinate for the consistency in your current one. Consistency holds significance if in case you switched to a new vendor for the current year reporting.
Many companies rely on ACAreporter for their reporting needs. If you need any assistance in ACA reporting. Contact us!