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ACA 1094/1095 Audit Services

In November 2017, the IRS started sending out Letter 226J penalty notices to employers.   At a threshold of 95% in 2016, there is very little room for error and potentially very high penalty fees.  With only a short 30 day reply window to Letter 226J notices, do you really want to rush your analysis.   Better yet, when you look back, did you honestly ever think the IRS would be issuing these notices? If not, are you confident your team provided 100% accurate data, especially related to employees who worked part-time, or started or ended employment at busy times of the year for your HR team?

At the end of the day, we can provide cost-effective audit services to find these potential data errors, and if/when the IRS comes knocking at the door, you are not only prepared, but you'll also be sleeping at night knowing this isn't going to be an issue as you proactively fixed it -- with our help throughout this process.

We have put together 3 audit services, leveraging our Smart1095 engine, focused on Letter 226J problem areas. Additional traditional audit services are available, too.

[1] Recipient Eligibility Accuracy Re-Calculator

Are you worried about Penalty A (70% offer threshold in 2015 and 95% in 2016/2017)?  Do you have 100% confidence all ACA eligible employees were identified and offered coverage in any given calendar year? Are you worried that you’re lacking sufficient IRS Letter 226J support?

Using our Smart1095 engine, our data-driven audit methodology independently and objectively recalculates recipient eligibility.


  •   What You Get

An independent and objective list of eligible recipients for each of the respective Measurement Periods for the respective reporting year(s).

We then compare this list to what you officially reported, and, if interested, we can then help you resolve the individual employee inconsistencies if threshold percentages are not met.


  • What We Need

To proceed we simple need: ACA calendaring (i.e. Measurement Periods), Census data, Benefits data and Hours Worked data.   In the event waiver information is maintained outside of your PR/HR system, we also need a list of recipients that waived coverage.

[2] Data & Process Review (High-Level Internal Controls Audit)

Would you like high-level assurance about your internal reporting process, as well as if your 1095/1094 platform (vendor, software) produced information sent to the IRS that was structurally accurate?

Using our Smart1095 system, we can painlessly take your submitted data to produce a report that provides top-line data summaries that can uncover systemic data problems.


  •   What You Get

We’ll provide an independent and objective set of line 14 Offer of Coverage and line 16 Employee Status Control Counts (by distinct code value) and will compare these expected summary numbers to what was submitted to find any statistically relevant anomalies.


  • What We Need

To proceed we simply need: Census data and Benefits data as well as some high-level information about the plan, such as the plan’s characteristics (e.g., MV, MEC, Offered to All, Premium), waiting period and benefits termination rules. In the event waiver information is maintained outside of your PR/HR system, we also need a list of recipients that waived coverage.

[3] Proactive Data Analysis & Data Process Improvements (Detailed Audit)

Get ahead of the IRS. Let us dive into your data, expose potential data problems and help you fix them in advance (and not within your 30 day Letter 226J reply window).

If you already received Letter 226J and/or know your 2016 effort was sub-par, how confident are you that what you submitted for previous years is factually correct?

We can perform a full detailed audit tailored to your precise needs.  Using our Smart1095 system, however, will make this process far more economical for you and us!

  •   What You Get

An independent and objective assessment and improvement strategy, if needed.    Deliverables include tailored data reports that can be provided to the IRS in the event you receive a Letter 226J, and an in-depth audit report outlining steps you need to take to assure compliant 1094/1095 forms in the future.

  • What We Need

To proceed we need to interview your team, your data, plan design, and submitted IRS reports.

Please contact us at or call us at 1-855-948-5300

for a confidential discussion


Everything you'd like to know about the benefits of our ACA audit services

It’s really quite simple –

  • The regulations are complicated
  • ACA IRS reporting is new
  • Fines and penalties are very high
  • Vendors haven’t audited their own products
  • There are many moving parts
  • Your job could be at risk

Since your employer/vendor just recently processed these forms the information should be readily available.  If you’re seeking a sample-based audit, our sample audit report can be delivered in less than 4 weeks.  If you’re seeking a 100% data compare audit, than this will likely take more time unless all of the data can be furnished right away.

That all depends upon the comprehensive nature and integrity of your data and well as the importance of quality assurance to your 1095 vendor or software company that is producing your forms.

Given the complexity of ACA IRS reporting you really need a specialist that understands all the nuances of the regulations.

How Does the ACA Audit Work?

  • Employer profile
  • Aggregated ALEs
  • Plan design
  • HR/Benefits data
  • 1095 output
  • Scenarios
  • Data load
  • Expected results
  • Actual results
  • Exceptions
  • Avoided fines
  • Aggregated ALEs
  • At-risk employees
  • Offer of coverage
  • Monthly premium
  • Employee status
  • Dependents