Are You ACA Audit-Ready?
The IRS has announced a 33% staff increase over two years. The new staff will be assigned to multiple tax departments, including ACA reporting.
There are 131 valid code combinations for just one month of ACA reporting—are you trusting an ACA compliance expert, a vendor, or a current software provider simply doing it to "check a box?" With no more good-faith relief, the stakes are too high, and the financial risk is substantial.
Fast forward to today, and the stakes for non-compliance have only grown higher. Here’s why ACA compliance audits are now more important than ever—and why your organization should prioritize them over traditional financial audits.
The form's line 14 and line 16 codes are essential in demonstrating that employers offer the right healthcare coverage. Still, with 131 valid combinations of codes for just one month of reporting, it’s easy to see why this process can be daunting for many companies and even software solutions.
These 131 valid combinations are based on the logical constraints and specific IRS guidelines that dictate how Line 14 (offer of coverage) and Line 16 (safe harbor or reason for no coverage) codes can be paired. Let’s explain what this means for your business and how to stay compliant with ACA reporting.
The Complexity of 131 Valid Code Combinations
With 131 valid combinations of Line 14 and Line 16 codes per employee per month, it becomes clear how intricate ACA reporting can be. These combinations arise from the numerous coverage scenarios that can exist in any given month for an employee—whether they are offered minimum essential coverage, accept the offer, or fall into a category that exempts them from coverage, such as a waiting period or affordability exemption.
For example:
An employee might receive an offer of minimum essential coverage that meets the minimum value (Line 14, Code 1A), but they decline it. In this case, Line 16 might need to reflect an affordability safe harbor (Code 2F, 2G, or 2H).
Alternatively, if the employee is in a limited non-assessment period or the employer did not offer coverage, different combinations of Line 14 and Line 16 would apply.
Every one of these scenarios needs to be carefully considered to avoid inaccuracies.
Why Mistakes Happen
Given the sheer number of possible valid combinations, it’s easy for mistakes to happen. Many employers struggle to determine the correct pairing of codes each month, leading to incorrect filings. This can trigger costly IRS penalties, including $620 per employee for incorrect filings when considering both the forms submitted to the IRS and those provided to employees.
The Risk of Non-Compliance
Additionally, there is no statute of limitations on ACA penalties, meaning the IRS can seek Employer Shared Responsibility Payments (ESRPs) for past reporting errors indefinitely. This underscores the importance of accurate and compliant reporting every year.
How to Stay ACA Compliant: Navigating the 131 Code Combinations
Ensuring ACA compliance with these complex code combinations requires thoroughly understanding IRS guidelines and carefully reviewing your healthcare offerings and employee statuses. Here are a few ways to navigate the complexity:
1. Leverage Technology: Automating your ACA reporting can significantly reduce the risk of errors. Many software solutions can help manage and match each employee's correct Line 14 and Line 16 codes.
2. Complete Data Audits: Does your software solution provide data validation and audit before generating the codes and forms? This helps identify potential errors in your reporting before they trigger IRS penalties. Regularly data auditing your ACA filings ensures that your Line 14 and Line 16 combinations are accurate and compliant.
3. Get Expert Assistance: ACA compliance is a moving target, and as the IRS continues to evolve its enforcement efforts, it’s important to have experts on your side. Working with a dedicated ACA compliance team can help you stay ahead of the curve and avoid costly mistakes.
Final Thoughts: Mastering ACA Compliance
The 131 valid combinations of Line 14 and Line 16 codes on Form 1095-C demonstrate how nuanced ACA compliance can be. With the IRS increasing its scrutiny of employer filings, ensuring these codes are accurate is critical to avoiding penalties and safeguarding your business.
Employers who understand and properly manage these code combinations are in the best position to maintain compliance, reduce the risk of penalties, and focus on what matters most—running their business. If your company hasn’t implemented a strategy to ensure accurate ACA reporting, now is the time to consider.
ACA TRACK
ACA TRACK goes beyond basic compliance by providing a comprehensive data review that meticulously examines every line item of your employee data. Our system automatically scans for conflicts, missing information, or blank fields that could lead to costly penalties. This advanced feature ensures no detail is overlooked, identifying discrepancies down to the specific individual.