Mailing a 1094-C
The due date for paper returns of Form 1094-C is May 31, 2016. If your customers have fewer than 250 submissions of Form 1095-C they can mail them along with their 1094-C transmittal form to the IRS – and they can do so now.
The functionality to create a paper version of Form 1094-C is already in Integrity Data's software, whether customers have the cloud or the on-premises version. If they print the 1094-C and it is blank, review setups in the 1094-C Prerequisites section of the software.
Electronically filing a 1094-C
The due date for electronic returns is June 30, 2016. If your customers have 250 or more 1095-Cs, they are required to electronically file them and their transmittal, Form 1094-C, with the IRS. Corrections can be made after June 30, provided there was a filing before June 30.
Work on the functionality to create and send an electronic version of Form 1094-C that meets the latest IRS specifications for direct transmissions is Integrity Data's highest priority. Functionality should ready by April, provided there are no IRS delays.
By "direct transmissions," Integrity Data means functionality that allows your customer - from within their system and without use of their own ACA-specific Transmitter Control Code (TCC) - to:
Send a 1094-C to the IRS's new clearinghouse for ACA returns - without sweating the process of a separate upload
Have timely access to electronic messages, such as error notifications, concerning all their 1095-C and 1094-C submissions.
I have a 1A in Line 14 and Line 16 is blank. Is this correct? I thought blanks in Line 16 were bad.
On Jan 25, 2016, the IRS said that when you have a Qualifying Offer - Code 1A on Line 14 - you should have a blank on Line 16. For details on this change in IRS guidance, check out this blog post.
Why do I have a 1H/2B for the month an employee was terminated?
Integrity Data’s ACA Compliance Solution automatically enters 1H and 2B for that month based on the following IRS directive:
“If the coverage or offer of coverage would have continued if the employee had not terminated employment during the month, the ALE member will be eligible for relief under section 4980H for that employee’s last month of employment. In that case, the ALE member should enter code 2B, on line 16 for that month.”
Once you have picked either the monthly or the look-back measurement method for determining eligibility for coverage, can you change your choice from year to year – or do you have to stay with that method forever?
If using the monthly measurement method instead of the look-back measurement method, please review when we must offer them coverage.
Please make sure that your on have the latest update to Integrity Data's code; the most recent update to our on-premises version was posted to http://www.integrity-data.com/download-software/ on Tuesday, February 23, 2016.
If you do not have the update, please download it and, if needed, reach our Support team at firstname.lastname@example.org.