Bracing for an ACA-form boomerang: Next steps for undeliverable 1095-Cs

Bracing for an ACA-form boomerang: Next steps for undeliverable 1095-Cs

By Helen Karakoudas | ACA Education Director, Integrity Data
March 11, 2016

Whether you have already sent 1095-C forms to employees – or are close to getting them postmarked by March 31, 2016, be prepared for one more possible Affordable Care Act reporting to-do this year:

  • Managing employee forms for ACA compliance that happen to land right back in your office mail.
Undeliverable 1095-C_Integrity Data ACA Compliance

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Yes, for as much as a sense of accomplishment is so needed in this first production season for the anxiety-stirring 1095-C forms, issues that have nothing to do with codes in Lines 14 and 16 may keep you from finally sighing, “Done!”

Your last 1095-C teeth-gritting moment for Tax Year 2015 may trace to a matter as basic as a dated mailing address for a former employee – someone you just can’t track down on the job to hand them the form in person.

Ah, Murphy’s Law in for ACA reporting.

What to do when a 1095-C cannot be delivered?

Given that there is no definitive IRS guidance – yet – on this matter, we recommend turning to the real-world problem-solving that we find from a thought leader in the employee benefits community.

A writer for the International Foundation of Employee Benefit Plans (IFEBP) advises the following next steps for undeliverable 1095-Cs:

  • After attempting to send the 1095-C and documenting the attempt, you would be wise to keep evidence of your attempt, and keep copies of each Form 1095-C available or accessible to provide to individuals who request theirs at a later date,” says Lois Mathis-Gleason, IFEBP’s manager of reference/research services.
  • A possible course of action,” adds Mathis-Gleason, who is a CEBS (Certified Employee Benefits Specialist), “would be following IRS instructions for undeliverable W-2 forms. The 2016 instructions state on Page 7, ‘Keep for 4 years any employee copies of Forms W-2 that you tried to but could not deliver.’ ”

Clarity on Form 1095-C accessibility

Know that in addition to the physical file copy of each returned 1095-C that would be kept, users of Integrity Data’s ACA Compliance Solution can access digital copies of every 1095-C printed.

Should a former employee who has moved (to an address that you do not have) circle back and request the 1095-C form that they did not receive, there is the ability to go into our ACA reporting software and print a copy of their missing form. Though such functionality may not be available is all ACA solutions, it is in our software. We not only process payroll and benefits data for form distribution and filings, but also store the processed data for what is documented on the forms, thereby providing an audit-ready ACA system of record.

Learn more about Integrity Data’s ACA Compliance Solution here.

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