Compliance Connection Proposed ACA Health Coverage Reporting Relief Submitted by Tom Sledge, Arkansas State Manager, American Fidelity Assurance Co. New proposed rules give employers more time to distribute Affordable Care Act (ACA) forms, but no more “good faith” relief for reporting errors. Automatic 30-Day Extension to Furnish Forms 1095-B and -C The Internal Revenue Service (IRS) has proposed regulations that, once finalized, will make permanent an automatic 30-day extension for providing Forms 1095-B and C to individuals. A similar extension has been granted for the past several years. This is good news for employers and insurers who in past years have been forced to wait until late in the busy end-of-year tax reporting season to find out if an extension would apply. Action Required Deadline Furnish individual 1095 forms March 2, 2022 File on paper with IRS February 28, 2022 File electronically with IRS March 31, 2022 Alternate Furnishing Method for Part-Time Employees Covered Under Self-Insured Plan The proposed regulations do not change any of the compliance responsibilities applicable to large employers, who must still issue Form 1095-C to each full-time employee and file copies of each form with the IRS, even if the employee waived coverage under the employer’s plan.
The new rules do, however, propose to make permanent the alternative furnishing method available in past tax years for forms provided to part-time employees (and to non-employees such as COBRA participants) enrolled in self-insured coverage. The alternative furnishing method involves making copies of 1095 forms available upon request, publishing a statement on the employer’s website, and maintaining this information until at least October 15 each year. Employers wishing to explore the alternative method are encouraged to closely review the requirements. ACA Compliance Should Remain Top Priority While this relief is welcome, employers should stay mindful of ACA responsibilities for three reasons: 1. There is no extension for filing forms with the IRS; that deadline remains the same. 2. The proposed regulations emphasize that the IRS will no longer grant “good faith effort” relief for minor ACA reporting errors. ACA reporting penalties can add up fast. Even if affordable coverage is offered to all full-time employees, employers still face stiff monetary penalties for late, inaccurate, or incomplete forms. Employers are encouraged to work closely with their vendors, service providers, or internal ACA reporting team to ensure a smooth and successful ACA reporting process.
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Click Here to Read About This Month’s Topics • Interoperability: Seamlessly Sharing Data, Content, and Services Within School District Systems or Applications • Leadership Strategies for Scaling, Sustaining, and Budgeting for Education Technology Innovations • CoSN Critical Focus Area One Pager - Strategic Technology Planning and Investment, Aligning Priorities, Balancing Choice Cost & Outcomes • Financing Technology Innovations - Strategies and Tools • CoSN 2022 Annual Conference • CoSN Membership 6