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September 8, 2016

What We Learned About 2015’s ACA IRS Reporting Efforts

In conjunction with an early September webinar, “ACA Reporting Getting Ready For 2017” with Epstein Becker Green, ACA Managed Services, asked participants to complete a survey on the ACA reporting experience last year. Here is a summary of the results:

2015 ACA Survey Results – A Tale of 2 Reporting Seasons

First of all, a big thank you to the many survey takers!

Statement of the obvious alert – the 2015 reporting effort was challenging to say the least. The struggle was intense. Bad data, regulation ambiguity, varying interpretations and threatening IRS penalties translated into the “perfect storm.” The good news is 2015 was a best efforts year. Unfortunately, best efforts are behind us and 2016 marks the start of rigorous scrutiny along with material fines for non-compliance. Survey highlights follow:

1. “Struggling” does not discriminate. Employers of all sizes in all industries struggled. Even employers with integrated HR, PR and Benefits systems as well as employers with fully outsourced systems had many challenges.

2. The fruits of the struggle did not always translate to peace of mind.

    • 67% of the responders were either unsure or did not have high levels of confidence re: 1095 forms and 1094 filing quality.

3. Employers knew they had data issues, but submitted anyway. When one reads between the lines it appears as if these employers, given their interpretation of “best efforts” did not think the IRS would issue penalties to them for this past year’s effort on average, the responders feel that their data quality/integrity only measures 80%.

    • 33% of the responders wish they could have a way to identify IRS penalty risk prior to publishing the 1095 forms and sending the 1094 transmittal to the IRS.


    • 65% of responders recognize that data clean-up is much needed and many of the responders have started to remedy the source data.

4. In fact, in spite of these struggles and the data quality concerns, everyone seemed to think it would be others who would receive penalties, not them.

    • 75% of the responders would be surprised if their employers received an IRS penalty

5. Not surprising, the size of the employer influenced who they would call:

    • The larger employers would retain counsel


    • The smaller employers would consult with their broker

(side comment - not really sure how a broker would handle this particularly since 1) their attorneys don’t provide these services and 2) smaller brokerage firms do not have attorneys on retainer). BTW, we provide these “fix-it” services.

6. Selecting a vendor who understands data management is key

    • 70% of the survey responders put Data Management as the number 1 most important characteristic their ACA IRS reporting vendor could have.


    • The other important characteristics include: Quality Assurance, ACA Legal Expertise and Data Security. Price was near the bottom of the list.

Again, many thank yous to the many survey responders. If you have any questions regarding survey results by industry or employer size please send us an email to