C IRS Filing ACA Reports

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1 Ultra32 Affordable Care Act Option User Reference Guide 1095-C IRS Filing ACA Reports The IRS requires submitting to them 1095-C form information for all employees that had a Full Time Employee Status for any month of the calendar year reporting period. One 1094-C Form is also required to be submitted as a totals report together with any group of 1095-C s file. The IRS permits paper filing for employers reporting 250 or less employees. Everyone is encouraged and larger employers are required to file electronically. Ultra32 provides options to generate filings for both methods. The process to create an IRS filing is an extension to the Ultra32 Employee 1095-C Print process. First please follow the process to prepare the printing of your employee 1095-C forms by running Steps 1 and Steps 2 of the print process. Then instead of skipping Steps 3, 4, and 5 you must complete them in order to define additional information to complete the 1094-C summary submittal form. Then on the Final Step Screen the Report Selection pull-down can be used to selected options to either print the forms or create electronic submittal files. Before completing the remaining steps it is necessary to first have totals information available from the 1095-C Totals Report. This report can be printed by box checking the Include the Totals Report from the 1095-C report print screen as shown below. 1 of 20

2 When you wish to print the Totals Report you do not have to print the 1095-C forms. Instead of selecting the default option for All Generated Reports click the pull down button and select 1095-C Totals Report as shown: 2 of 20

3 Step 3: Additional 1094-C Information is separated into three Parts. Each part is explained below. Part I. This section must be completed for all transmittal s, not just the authoritative transmittal. Line 18 requires input of the number of employee form records that are included in this transmittal. This total is available from the 1095-C Totals Report. Line 19. Check the yes box only if this transmittal is an authoritative transmittal for this ALE Member. An ALE Member is permitted to submit 1095-C data to the IRS in multiple batches. This is often done when an employer manages employee data for different groups of employees separately for different divisions, locations, or systems. In the case when multiple transmittal s are to be sent then one transmittal must be designated as the authoritative transmittal. This transmittal must include extra totals information that includes grand totals including all other transmittal s for the same tax id ALE Member. 3 of 20

4 If Line 19 is not selected then you should skip Parts II, III, and IV (the rest of Step 3 and all of Steps 4 and 5) and just click on the Last Page button to jump the Final Step. If you do check Box 19 then continue on to Part II on the Next page. Part II. ALE Member Information. Line 20. This number includes the total number of 1095-C forms attached to this transmittal (Line 18) plus the total number of 1095-C forms submitted in separate non-authoritative transmittals for the same tax id. Line 21. If this ALE Member is part of an Aggregated ALE Group (multiple tax id s under the same ownership common control) and this is both the authoritative transmittal for the ALE Member (tax id) and authoritative transmittal for all group ALE Members (for all tax id s in the same control group) then check the Yes box. If you do not check this box then you do not have to fill in any portion of Part IV or check Yes for any row in Part III column D Line 22. Certifications of Eligibility. Check each box that applies to the ALE Member for the reporting calendar year. It is acceptable and possible that more than one box may apply and be selected. Please consult IRS guidance, or an ACA adviser familiar with the policies followed to make offers to ensure the correct boxes if any are selected. Box A: Qualifying Offer Method. Check this box if this ALE member chose to follow the Qualifying Offer Method for all twelve months of the year to offer full time employees coverage that meets the requirements followed to report on employee Form 1095-C Line 14 Offer of Coverage as Code 1A Qualifying offer of coverage. This method enables the simplified employee reporting using a generic pro forma letter to employees instead of issuing each employee a 1095-C form. A 1095-C form still must be filed with the IRS. Box B: Qualifying Offer Method Transition Relief. For 2015 only check this box if this ALE member certifies it made Qualifying Offers for one or more months of 2015 to at least 95% of its full-time employees. This is an alternate less stringent method which also enables the simplified employee reporting using a generic pro forma letter to employees instead of issuing each employee a 1095-C form. A 1095-C form still must be filed with the IRS. Box C: Section 4980H Transition Relief. In 2015 generally everyone should check this box. Checking this box for employers with 100 or more FTE employees is your request to have your total FTE count reduced by 80 instead of the standard 30 reduction before calculating penalties and for substantially all of your full time population to be set at 70% of your employees instead of 95%. For employers with less FTE employees this box is your request to be excused from the Pay or Play penalties for of 20

5 Box D: 98% Offer Method. Check this box if this ALE member chose to follow the 98% Offer Method for all months of the calendar year, offering affordable health coverage providing minimum value to at least 98% of its employees for whom it is filing a Form 1095-C employee statement, and offered minimum essential coverage to those employees dependents. This method allows the employer to not have to determine and input the Full-Time Employee count in Part III, column (b) of the authoritative Form 1094-C. Step 4: Additional 1094-C Information Part III ALE Member Information Monthly In this part employers report changes in FTE population, total employee count, and additional details for aggregate groups and transition relief codes. Each column should be set individually for each month except when the same setting applies to all months in that column in which case the 12 Months row should be used and the monthly rows should be left empty. Column (a) Minimum Essential Coverage Offer Indicator On a monthly basis, the employer should check box Yes if they have offered qualifying healthcare benefits to at least 95% of full-time qualified employees that are not in a waiting period. Column (b) Full-Time Employee Count for ALE Member Enter in this column the number of full-time employees each month who have a Full Time Status in an active stability period and are not in a non-assessment period (allowed waiting period). This monthly total can be found in the 1095-C Totals Report. For an ALE Member with multiple transmittals the totals must be combined and entered as a combined sum on the authoritative transmittal only. Column (c) Total Employee Count for ALE Member Enter in this column the total number of employees who worked each month regardless of their status in that month. The IRS allows employers to select from multiple methods of tallying each monthly total. Ultra32 accommodates this by allowing you to select whatever payroll activity date range you desire to used for counting each calendar month of the year. Based on your date range selections the monthly amounts will listed on the 1095-C Totals Report. For an ALE Member with multiple transmittals the totals must be combined and entered as a combined sum on the authoritative transmittal only. Column (d) Aggregated Group Indicator If the ALE Member is part of an aggregate group in any month click the boxes that apply. This usually is set to Yes or not the same using the All 12 Months Row. Column (e) Section 4980H Transition Relief Indicator Refer back to Part II Line 22 Box C. If you did not check Box C then leave the column blank. If you did check Box C and you had less than 100 FTE s then write in code A for every month that you are taking transition relief (usually All 12 Months). If you did check Box C and you have 100 or more FTE s then write in code B for all months that apply. (usually all 12 Months). 5 of 20

6 Below is an example of an employer with less than 100 FTE s for 2014 that is not part of an aggregated group. They are electing to take transition relief for employers with FTE s. Step 5: Additional 1094-C Information (continued) Part IV Other ALE Members of Aggregated Group Only complete Part IV if you checked the Line 21 box above, otherwise click next to skip to the Last Page. Part IV Identifies all other ALE Members of an Aggregated Group of employers under control of the same ownership group. Below is an example of four EIN Tax Id Group. Each ALE Member a part of the same aggregated Group as the ALE Member submitting the 1094-C should be listed. Exclude listing the reporting ALE Members own information. Include the entities Name and Tax Id. ALE Members are to be listed from largest full time employee count to smallest. Use the Order field to assign each record an ascending number to be used to to determine the displayed sort order. 6 of 20

7 Generating Electronic Files Ultra32 supports generating output compliant for both paper and electronic filing. The IRS permits paper filing for ALE Members transmitting 250 or less forms. All size employers are eligible to electronically file. Paper Filing Paper filing must be done in two steps. The first Step is to select the 1095-C Employer Form Print for IRS (1095CFULL) to generate all the individual employee 1095-C Forms. The second step is to select the 1094-C Employer Form Print to generate the 1094-C Transmittal Form. Paper Filing requires printing of data onto appropriate pre-printed forms. Electronic Filing Electronic filing creates two output files. One contains 1094-C form data together with all employee 1095-C form data. The second file is called a manifest file which contains additional electronic filing control information only. Ultra32 supports creating both files but does not include support to transmit and confirm receipt and acceptance of the filing with the IRS. You must register with the IRS to be authorized to electronically file yourself using their secure web portal. This process requires obtaining a registration confirmation via U.S. Postal Mail so expect it to take at least 1 week to complete the process. CCS has the ability to transmit for you but a service fee does apply for this service. Please contact CCS us for additional information. Transmitter Control Code Before creating any electronic submittal files you must specify the authorized Transmitter Control Code that will be used for login and submittal to the IRS ACA submittal web portal. Self filers can apply for and be authorized to self file using an Issuer Transmitter Control Code (TCC). Or files can be submitted by a third party transmitter in which case the TCC info to be specified will be provided to 7 of 20

8 you by the transmitter. The Transmitter can be defined by clicking on the ACA Transmitter menu as shown below: 8 of 20

9 Then from the Transmitter Data entry Screen click on the New Button on the toolbar to create a new Transmitter Record: 9 of 20

10 Then you will be able to set the Transmitter Control Code (TCC), Transmitter EIN, and Transmitter Company Name as registered with the IRS. If you are self filer this information will be that used to register as a self Issuer with the IRS. Otherwise this information will be provided by your transmitter. Test File Transmission If you have obtained your own self-issuer TCC then you are required to do a test file transmission and have it accepted before your TCC status is changed from Test to Production to allow filing of a live ACA submittal. If you are using a third party to transmit your files then you may skip the test file transmission steps. After completing registration to self file using an Issuer TCC your Id is put in Test Status. The IRS requires that you first complete a test upload to their Test web site and then wait for approval confirmation before your registration is changed from Test to Production status. 10 of 20

11 From the ACA Transmitter Data Entry Record screen ensure the correct TCC record id displayed then click on the Create Test File button. The test files will be auto created and placed into your C:\ CCSLOCAL\ExportFiles\ACATest folder for communication testing. To submit your test files visit this link: First, you will be required to login with your id and password. Then you will be prompted to select which authorized company you are reporting for. Then you may be prompted to select the year you are submitting a test transmission. Then you will see the Main ACA Transmission File Upload Screen. At the top first click to browse and select the Manifest test file. Then click to browse and select the corresponding ACA Form File. Then click on the Transmit button to start the upload. Then wait patiently for the upload to complete. Look for a confirmation that the upload was successfully completed. If receipt of the file is confirmed then you will be provided a Receipt Id. IT IS VERY IMPORTANT TO ALWAYS KEEP RECORD OF RECEIPT ID s. Print the screen with the Receipt Id. It is necessary to reference the Receipt Id to lookup the processing status later. If upload of your transmission is not confirmed then you will receive some kind of error notice. To investigate any problems record any error code and message provided. It is highly recommended that you print the error message screen. Depending on the error you need to take whatever corrective actions necessary, and then attempt to resubmit. Test File Accepted Use the same IRS web site used to upload the test file to check the status of the upload. You must enter your TCC Id and Receipt Id to check the status. After several minutes or possibly many hours the Test File status will change from Processed to Accepted or Rejected. Once your test file is Accepted then you must call the IRS to request your TCC be changed from Test to Production status. You may contact the IRS at x3. DO NOT SEND A LIVE SUBMITTAL UNTIL YOUR TCC IS SWITCHED TO PRODUCTION, IT WILL BE REJECTED IF YOU TRY. You may verify your TCC has been changed from Test to Production status be logging into the web site you originally used to request access to the IRS e-services system. You need to logon to your e-services Account. Go to : Click: Access e-services Click: Login or Register Click: (ACA) your company name... Click: Application Click: ACA Application for TCC In the Processed Applications section, click on the View Summary Page actions button () 11 of 20

12 You will find the status of your Transmitter Control Code in the TCC Information section and Form T/P Indicators: Section. T = TEST and P = PRODUCTION. The T/P indicator should be P for both Issuer Role records. Generating a 1095-C/1094-C Transmittal File Set After Setting the Transmitter record and completing the test process if you are a self-issuer transmitter then you are ready to create your first live submittal files. So return to the Last Page of the 1095-C Print Menu. Then select the 1094-C / 1095-C Electronic File for IRS Report Selection as shown below. On the next screen ensure that the proper For Transmitter Control Code is selected. And for an initial submission all check boxes should be Unselected. Then click on the Generate button. 12 of 20

13 Your submittal files will be created and placed in C:\CCSLOCAL\EXPORTFILES\ACAFiles\. If any critical or possible errors are found in the filing then a warning will pop-up like this: 13 of 20

14 Select the option to stop the creation of the file and display the error report. Some errors are critical and will prevent the IRS from either accepting the file upload or will definitely result in rejection. Other issues reported may only be warnings or possible errors or concerns of unusual circumstances. These should be reviewed but possibly may be accepted as is without cause of full or partial rejection. After reviewing and possibly correcting issues on the error report you can re-run the process and if errors continue you may decide to ignore them and proceed with creating your submittal files. Your submittal files will be created and a confirmation screen will pop-up telling you the name and place you can fine the files as shown below: 14 of 20

15 Self Issuer Uploading Files to the IRS using their UI Website The IRS provides a User Interface (UI) web portal to upload 1095-C/1094-C submittal files. For each submittal Ultra32 creates a group of three files like the examples below: 1) Manifest_1094C_Request_BC3Y3_ T Z.xml 2) 1094C_Request_BC3Y3_ T Z.xml 3) U32Log_DO_NOT_FILE_THIS_999999_TMPDEMO_BC3Y3_ T Z.txt The ending of each file in a group is a matching transmission id and identifies one submittal file group. 15 of 20

16 The first file whose prefix is always Manifest_1094C_Request is known as the manifest file. The second file whose prefix is always 1094C-Request is know as the Forms files. The third file whose prefix is U32Log_DO_NOT_FILE_THIS followed by the Ultra32 system license and the Ultra32 Data File Identifier is an informational only file to help identify the originating source for a submittal file group. Self Issuer Where to Go to Upload Visit the IRS Production ACA UI Web Site at: First, you will be required to login with your id and password. Then you will be prompted to select which authorized company you are reporting for. Then you may be prompted to select which tax year you are submitting a test transmission for. Then you will see the Main ACA Transmission File Upload Screen. At the top first click to browse and select the Manifest test file. Then click to browse and select the corresponding ACA Form File. Then click on the Transmit button to start the upload. Then wait patiently for the upload to complete. Look for a confirmation that the upload was successfully completed. Otherwise you may see that your transmission was aborted due to a problem with your upload. Or it is possible that you could see a failure due to some kind of system issue. To investigate any problems it is highly recommended that you print any failure screens. If you receive an error investigate the cause, make any necessary corrections, and then attempt to resubmit again. Once you successfully complete an upload then you will be provided a confirmation screen with a Receipt Id. IT IS VERY IMPORTANT TO ALWAYS KEEP RECORD OF THIS RECEIPT ID. Print the screen with the Receipt Id. It is required to look-up the processing status of the submittal. If upload of your transmission is not confirmed then you will receive some kind of error notice. This condition is referred to as Portal Rejection. To investigate any problems record any error code and message provided. It is highly recommended that you print the error message screen. Depending on the error you need to take whatever corrective actions necessary, and then attempt to resubmit. Tracking the status of your Submittals From the TCC transmitter screen you may double click on Transmittal record to record the Receipt Id, the submittal date and the last verified Processing status as shown below. After updating the screen click Save and then Close. 16 of 20

17 Checking the status of your Submittal Use the same IRS web site used to upload the test file to check the status of the upload: After logging in go to the main ACA Information Returns Screen and select the second Option to check transmission status. Checking the status requires input of your TCC and your submittal Receipt Id. After PROCESSING the status will change to ACCEPTED, or ACCEPTED WITH ERRORS or REJECTED. This may take several hours or several days. Within Ultra32 you should record the most current status of each submittal Receipt Id. 17 of 20

18 Accepted Status Congratulations! Your submittal was accepted. You are done. Accepted with Errors Status A limited number of errors were found in your filing. Your submission is being accepted but errors did exist. Most commonly these errors are AIRTN500 TIN Validation Failed errors meaning a Social Security Number did not match an employee s name according to IRS records. The IRS has advised that if the employer made a good faith effort to validate the information then the error does not have to be corrected. But if the employee is still active the employer should have a documented process to attempt to correct TIN errors before the next filing. Please refer to IRS guidance or a tax advisor for additional guidance. With Accepted with Error Status the correction process requires reporting of the entire original file along with the Record Id and corrective info of the records in need of correction. ULTRA32 DOES NOT PROVIDE SUPPORT FOR ELECTRONIC SUBMITTAL OF THESE TYPE OF CORRECTIONS. REMEMBER THESE CORRECTIONS ARE GENERALLY NOT REQUIRED TO BE SUBMITTED. To find out what employee records had errors from the IRS Transmission Status Details screen you must click on the download button to download the error file in XML File Format. An XML file can be difficult to read but it is manageable. The file can be opened with any text editor. Windows Wordpad is generally pre-installed and preferred over Notepad for reviewing the file. See the file sample below. For each error you will see a reference to a unique record id. The start of the record id will always be the receipt id. Then you will always see a separator character, then a 1 digit, then another separator character followed by a record number like: 1095C In this example the error is for record number of 20

19 On the TCC Transmission Data Entry Screen for the transmittal you can scroll through a list of all employee records to find the employee record in need of review for correction. Rejected Status Your filing had critical errors or exceeded the allowed threshold of minor errors such that the entire filing is being rejected. First, at the ACA Transmitter Data Entry Screen be sure to find your submittal record and change the Process Result Status to mark it as Rejected. Also ensure you previously defined the Receipt Id in the designated field. Then you must review the returned list of errors and change data in Ultra32. After completing these steps then you are ready to create a replacement submittal file. When you create your submittal file be sure at the bottom of the screen to check the box option to indicate that you are Replacing the Original transmission using the Replacement Process. The replacement submittal will then include required references to the original receipt id that has the rejected status. Portal Rejection Status Your filing had errors that prevented it from being allowed to be uploaded to the portal. First, at the ACA Transmitter Data Entry Screen be sure to find your submittal record and change the Process 19 of 20

20 Result Status to mark it as Portal Rejection, No Receipt Id. Then you must review the error message given to resolve it and then create the file again and try uploading again. When you create your submittal file be sure to check the box to mark that you are resubmitting the Original Transmission that was immediately declined and no receipt Id was issued. The replacement submittal will then include required references to the original filing that was portal rejected. 20 of 20