AIRMF3005 means

The value of the Manifest ‘TestFileCd’ must equal the value stored in the IRS’ database governing the status of the ‘FormsTypeCd’ .

You have to submit one communication test with the IRS.  Once you have submitted one Accepted file, you call the IRS at 866-937-4130 x1 x3 and ask them to move your TCC number from Test to Production.  If you are getting this error when submitting, your submitting a file with this XML code:

<p3:TestFileCd>P</p3:TestFileCd>

where P is Production but your TCC number is still identified as a T or Test.

The electronic submission process does not have a void option. You can, however, use the correction process to change data that was incorrectly filed on IRS Form 1095-B or Form 1095-C or to void a record.

Using the Correction Process to change data from an incorrectly filed 1095-B:

1. Check ‘CorrectedInd’

2. Revise Part IV to remove all covered individuals that were reported on the previously-accepted 1095-B and do not include the ‘CoveredIndividualGrp’ tags

1095-B Example Scenario: BBBB Insurance Company files a 1095-B for George Catoctin showing George and his three children were covered all year. After sending the return, they find that George should not have been sent a return since no one was covered during the tax year.

Remedy:  BBBB Insurance Company would correct this issue by sending a Corrected 1095-B to both George and to the IRS, removing George and his three children from the ‘CoveredIndividualGrp’ (leaving Part IV blank). When filing electronically, do not include ‘CoveredIndividualGrp’ tags.

Using the Correction Process to remove the record of coverage from an incorrectly filed 1095-C:

1. Check the ‘CorrectedInd’

2. Revise Part II to align with the [former] full-time employee’s actual status data

3. Uncheck the ‘CoveredIndividualInd’ checkbox

4. Revise Part III to remove all covered individuals that were reported on the previously-accepted 1095-C and do not include the ‘CoveredIndividualGrp’ tags

1095-C Example Scenario:  XYZ Plumbing files a 1095-C showing John Whitney, their Employee, was offered coverage and that John and his wife were covered all year. After sending the return to IRS, XYZ discovers that John had left the company in December of the previous year and that the 1095-C was sent in error.

Remedy:  XYZ would correct this issue by sending a Corrected 1095-C to both John and to the IRS with Part II and Part III filled out as follows:

• Line 14 would show Code”1H” in “All 12 Months” showing that John was not offered coverage.
• Line 15 would not be present, since there was no Offer of Coverage.
• Line 16 would show “2A” in “All 12 Months” showing that John was not employed during the year.
• Uncheck the ‘CoveredIndividualInd’ checkbox
• Remove John Whitney and his three children from the ‘CoveredIndividualGrp’ (Part III) and do not include the ‘CoveredIndividualGrp’ tags.

Updated June 15, 2016. Please reinstall the 1094/1095 software from this link

https://www.1099fire.com/try_now.htm

Reinstalling will give you the most current version that can prepare replacement and/or corrections.

Corrections are used to update an information return that was previously filed and Accepted (with or without errors) by the IRS, but contained erroneous information.  Corrections can fix errors reported by IRS or those discovered by Filers
independently. If a file is rejected by the IRS, you put together a replacement file.

Replacements: Transmitters can replace submissions which were rejected.  Its easy to do.

Prepare a new file.  Click on File Information Returns Electronically and a box will pop up. In the top left corner you will see this:

Select Replacement from the Transmission Type. Type in the Original Receipt ID that you received when your file was rejected.   That’s it.  You can now create the data file and manifest file and upload these replacement XML files.

Corrections: Corrections can be made to previous submissions that have been Accepted or Accepted With Errors.  If you transmit a file and it comes back as Accepted but later realize you transmitted erroneous data, you need to efile corrections as soon as possible.  Accepted With Errors will list your errors.  You can clean up your data and transmit a correction.

You only want to correct data which is erroneous.  If you submitted 100 records but 1 record had an error, you prepare a correction for this one record in error and transmit that. The IRS states “The Transmitter must furnish corrected statements (physical paper forms) to recipients as soon as possible” which means you have to print and mail a new 1095 form to the employee.

You can not transmit originals and corrections in the same file.  Corrections must be separate from original transmissions.

There are different types of corrections and we discuss each below.  We go from easy to hard in our discussion of correction types and follow up with examples.  If you have questions, ask anytime.  Technical support can be reached at support@1099fire.com and (608) 444-6575.

1094-B Corrections: Form 1094-B is the transmittal summary to the 1095-B forms.  If you look closely, the 1094-B form does not have a void or corrected check box at the top of the forms. You can’t paper file or efile corrections for IRS Form 1094-B.

1094-C Corrections: Form 1094-C is the transmittal summary to the 1095-C forms.  You can efile a correction for the 1094-C forms.

Here are the steps.

1. Do not include 1095-C records.

Put together an excel file with no 1095-C records and update the 1094-C data as much as you like. Import in the 1094-C data.

2. Select 1094-C Transmission Type.

Click on File Information Returns Electronically and you see a screen which looks like this

Select Correction (1094-C Record) as the Transmission Type.   Type in the Original Receipt ID that you are trying to correct. Type in the original payer name and original payer EIN.  If you transmitted a file and the original payer name or payer EIN was incorrect, type that incorrect information in here.  The Receipt ID, Original Payer Name and EIN helps the IRS pinpoint which 1094-C record to correct.

3. Efile.  Create the manifest and data file and transmit to the IRS.

1095-B, 1095-C Corrections:

Let’s consider an example as we go through 1095-B, 1095-C corrections.

1. Identify the errors. The most current IRS Test Scenario #3 has employees for the business Selitestthree. The correct data is:

Let’s make an intentional mistake and upload Teresa Southern with the SSN 111-00-0350.  We transmit and get these results:

Receipt ID: 1095C-16-00041297
Status: Accepted with Errors
AIRTN500 TIN Validation Failed

TIN Validation Failed means the name/TIN combination does not match IRS records (which for this case is true).  We can download the error report from the IRS and see

<UniqueRecordId>1095C-16-00041297|1|1</UniqueRecordId>
<ns2:ErrorMessageDetail>
<ns2:ErrorMessageCd>AIRTN500</ns2:ErrorMessageCd>
<ns2:ErrorMessageTxt>TIN Validation Failed</ns2:ErrorMessageTxt>
</ns2:ErrorMessageDetail>

I know, it looks confusing but this

1095C-16-00041297|1|1

means Receipt ID | 1094-C ID | 1095-C ID.  In more detail,

   Receipt ID is 1095C-16-00041297
   1094-C ID is 1 always (In theory, you can submit a data file with the 1094-C followed by its 1095-C records and then another 1094-C and its 1095-C records.  But with our software, we only submit one (1) 1094-C per data file and it’s followed by it’s 1095-C records.  So the 1094-C ID is always 1 or the 1st 1094-C in the data file.)
   1095-C ID of 1 (1st record is the error in this example.  If the 15th 1095-C had the error, then you would have typed 15 here.).

Together,

1095C-16-00041297|1|1

is the CorrectedUniqueRecordID.  Our first step is to identify the records that are in error and retain these CorrectedUniqueRecordIDs.

2. Prepare a subset of corrections.  Prepare a new excel file to import into the software.  Make changes to this subset of records.  If the SSN was incorrect, change it on this subset.  If the Plan Start Month was invalid, correct it now.  Make any and all changes you every wanted to make to these records that you are correcting.

To the far right of the excel file, add 6 extra columns namely First, Middle, Last, Suffix, TIN and CorrectedUniqueRecordID.  The far right columns will look something like this:

The IRS webinars say:

Key data fields from the original record to be correct, e.g. Recipient Name
and TIN. Note these fields are necessary to allow the IRS to associate the correction record even when the Unique ID’s don’t match.

If you had an incorrect name or incorrect TIN, type that in these extra columns so that the IRS can match up the incorrect name/TIN that was already submitted with what the IRS has on file.

3. Import the data into the software.

4. File 1095-C Corrections along with a 1094-C without with only Part I on the 1094-C completed.

Go to the 1094-C and Box 18 on the 1094-C.  Box 18 represents the number of records you are transmitting right now.  If you transmitted 3 employees and one 1 record is erroneous and you want to correct that one record, type 1 in Box 18 on Form 1094-C.  That represents the size of this small excel file.  Only complete Part I on the 1094-C.  Your not efiling a 1094-C correction; just 1095-C corrections.  A 1094-C correction would be a separate file/transmission.

5. Click on File Information Returns Electronically and a box will pop up. In the top left corner you will see this:

Change the Transmission Type from Original to 1095-B or 1095-C Correction.

That’s it.  You can now create the data file and manifest file and upload these correction XML files.

If your correction comes back as Accepted, your done.  If your correction comes back as Accepted With Errors, then you still have errors in that correction.  You can submit another correction.  Submit as many corrections as you like.

Please reinstall the 1904/1095 software from this link

https://www.1099fire.com/try_now.htm

Reinstalling will give you the most current version that can handle foreign employee mailing addresses.

1. Form 1095-C.  The employee address section looks like the following:

Type in or import in the best, most complete address you can.  In Box 5 State or province, type the 2-character province code only if the employee address is from Canada (CA).  If they are from any non-US country other than Canada, leave the province field empty.  The list of Canadian province codes are here

Alberta AB
British Columbia BC
Manitoba MB
New Brunswick NB
Newfoundland and Labrador NL
Northwest Territories NT
Nova Scotia NS
Nunavut NU
Ontario ON
Prince Edward Island PE
Quebec QC
Saskatchewan SK
Yukon YT

In Box 6, type the 2 character country code in the 1st box and the zip code in the 2nd box.  A list of country codes is here.  Blank means US so if they do have a US mailing address, just leave the 1st field in Box 6 blank.  US is also acceptable.

Click on File Information Returns Electronically and you will see this:

By default, the software assumes you have all US mailing addresses when efiling.  Its easier and faster to assume US mailing addresses. If you have employees with foreign mailing addresses, then put a check in the check box “Foreign Recipient Addresses” and the software will review each employee country code (which is the 1st field of Box 6).  Blank or US means the recipient has a US mailing address.  Any country code other than blank or US and the software will use the ForeignAddressGrp XML code.

2. Form 1095-B.   The employee section of IRS Form 1095-B looks like the following:

Again, type in anything you like in the City.  Type in a 2-character province code only if they are from Canada.  Type in the 2 character country code.

The April 26, 2016 IRS webinar says

The apostrophe is not allowed in AIR.

• However the escaped apostrophe (&apos) is allowed except in an
Individual’s name.
• For example, if a record has a last name data field containing an apostrophe, such
as “O’Malley”, the transmission cannot include the apostrophe or the escaped
apostrophe characters. The apostrophe must be stripped and the last name data
must be entered as “OMALLEY”. The transmission will be rejected, if the
apostrophe is used.

The IRS website has this information:

AIRMF3014
Manifest ‘ChecksumAugmentationNum’ must not match a ‘ChecksumAugmentationNum’ of any AIR transmission from the same ‘TCC’ previously accepted.

When the software creates a manifest file, there are two (2) unique identifiers.

1. UUID or Universally Unique Identifier.

The first unique identifier is about the 3rd line down and looks like

<p3:UniqueTransmissionId>84eab598-8fb9-4a26-978c-acedeb156a1b:SYS12:BB057::T</p3:UniqueTransmissionId>

In this example, this number

84eab598-8fb9-4a26-978c-acedeb156a1b

is a Universally Unique Identifier or UUID.  All you have to know is the UUID is a unique, lowercase 32 character value.  The software will generate a unique UUID everytime you create a new manifest and data file.  The IRS wont accept a manifest file with the same UUID.  This prevents users from uploading the same data twice.

2. ChecksumAugmentionNum.

The second unique identifier is toward the bottom of the manifest file and looks like

<p4:ChecksumAugmentationNum>209f3805f1dfe172462bead4f56a3c65</p4:ChecksumAugmentationNum>

This number is also 32 characters in length.  The 1095 software creates the data file.  It then uses the content of the data file to create this 32 character number (or Checksum).  The 1095 software will create the same ChecksumAugmentationNum when given the same data with no changes.  A Checksum is a way to find out if the data file already exists.  If you resubmit a file with the same Checksum number, you will get AIRMF3014 error.

This error will sometimes arises when you upload a replacement file.  It shouldnt because the replacement file has a few changes in the data file to make it different enough to generate a new Checksum.  But if it does, you can generate your own unique Checksum.  There are lots of websites online.  This link

http://www.miraclesalad.com/webtools/md5.php

has a Checksum generator.  Copy and paste the contents from the data file or type in some random text.  Generate a new Checksum and copy and replace the one that is currently in the manifest file.  Save and upload.  That new Checksum will be a new unique identifier to the IRS.

IRS webinars say:

Remember, you´re expected to file accurate information returns with the IRS and furnish a copy to the recipient by the due date.

As mentioned earlier, for 2016, the due dates for filing and furnishing these returns were extended.

Once the information returns have been filed with the IRS, you´re expected to file any corrections as soon as possible.

However, corrections filed prior to the due date with the IRS may be filed at any time prior to the due date.

Corrections filed after the due date should be filed as soon as possible.

The due date for efiling the 1094/1095 forms is June 30, 2016.  Efile corrections before or on the June 30, 2016 deadline.  The IRS states that corrections can be efiled after the due date but should be filed as soon as possible.

We can help prepare and efile corrections.  Call us at (480) 460-9311.

The 1095 software can handle foreign recipient or employee addresses easily.  This article discusses foreign employee addresses.

The 1095 software is not setup to handle foreign employer address.  To do this, you have to adjust the data and manifest file manually.  Here are the changes you need to make:

1. Use <ForeignMailingAddress>.

The data file has the 1094-C at the top and is followed by the 1095-C records.  The employer address on the 1094-C is listed 5-6 lines down from the top.  The employer address looks like

<MailingAddressGrp>
<USAddressGrp>
<AddressLine1Txt></AddressLine1Txt>
<irs:CityNm></irs:CityNm>
<USStateCd></USStateCd>
<irs:USZIPCd></irs:USZIPCd>
</USAddressGrp>
</MailingAddressGrp>

and you want to change this to

<MailingAddressGrp>
<ForeignAddressGrp>
<AddressLine1Txt></AddressLine1Txt>
<AddressLine2Txt><AddressLine2Txt>
<irs:CityNm></irs:CityNm>
<CountryCd></CountryCd>
<irs:ForeignProvinceNm></irs:ForeignProvinceNm>
<irs:ForeignPostalCd></irs:ForeignPostalCd>
</ForeignAddressGrp>
</MailingAddressGrp>

You dont have to use AddressLine2Txt or ForeignProvinceNm; both are optional.  But you do need everything else.

2. Adjust the manifest file.

The manifest file describes and defines the data file that is about to be sent.  Adjust the data file and go to File/Save.  Then right click on the data file and go to Properties and you see this

Write down the file size which in this case is 462974 (its not the size on disk but the file size).  Write that number down.  Open the manifest file and toward the bottom you see this:

AttachmentByteSizeNum has to equal the file size of the data file.  Adjust AttachmentByteSizeNum to match the new file size and dont use commas (just digits).  Go to File/Save to save.

We received this error when efiling ACA data:

AIRER602        Payload attachment error (MTOM) – unable to read the attachment

The IRS posted on the site irs.gov/air

06/22/2016 – Rejected Transmission without an Error Data File, Error Code or due
to Error Code AIRER602.  The IRS is currently investigating an internal system
error that results in an AIRER602 or a reject without an Error Code or Error Data File.

• If you receive an AIRER602, MTOM payload attachment error, ensure your transmission conforms to the guidance in Publication 5165, Section 4.2 and 4.3.
• If your file complies with the Publication 5165 guidance, or if your transmission was rejected without an Error Code or Error Data File; follow these instructions: Known Issue: Rejected Transmission without an Error Data File, Error Code or due to Error Code AIRER602.

The IRS posted this on June 30, 2016:

If you are an applicable large employer, self-insured employer, or other health coverage provider, the deadline to electronically file ACA information returns with the IRS is midnight ET on June 30, 2016.  The ACA Information Returns (AIR) system will remain up and running after the deadline.  If you are not able to submit all required ACA information returns by June 30, 2016, please complete the filing of your returns after the deadline.

It is important to note the following:

• The AIR system will continue to accept information returns filed after June 30, 2016.  In addition, you can still complete required system testing after June 30, 2016.
• If any of your transmissions or submissions was rejected by the AIR system, you have 60 days from the date of rejection to submit a replacement and have the rejected submission treated as timely filed.
• If you submitted and received “Accepted with Errors” messages, you may continue to submit corrections after June 30, 2016.

The IRS is aware that some filers are still in the process of completing their 2015 tax year filings.  As is the case for other information returns, penalties may be associated with the submission of the ACA information returns for failure to timely file required returns.  As the IRS has publicly stated in various forums in recent months, filers of Forms 1094-B, 1095-B, 1094-C and 1095-C that miss the June 30, 2016, due date will not generally be assessed late filing penalties under section 6721 if the reporting entity has made legitimate efforts to register with the AIR system and to file its information returns, and it continues to make such efforts and completes the process as soon as possible.   In addition, consistent with existing information reporting rules, filers that are assessed penalties may still meet the criteria for a reasonable cause waiver from the penalties.

If you are not an electronic filer and you missed the May 31, 2016, paper filing deadline for ACA information returns, you should also complete the filing of your paper returns as soon as possible.

AIRTIN500 – TIN Validation Failed is a common error from ACA e-filing.

TIN Validation Failed means that the last name and SSN of a 1095 record that you transmitted does not match IRS records.  It could be the employee name and SSN is not matching IRS records but it could also mean that one or more of the covered individuals of that employee is not matching. The IRS specifies which 1095 record is in error but doesn’t specify which name/SSN is not matching.

You need to correct TIN Validation errors.  Tax year 2015 is the non-penalty year and the IRS starts off nice by ‘Accepting With Errors’ files with TIN validation errors.  From experiences with other information returns, the IRS starts off nice and they gradually move toward:

1. Asking the employer or payer to withhold money from the recipient and send that money to the IRS until the name/SSN matches IRS records or,
2. Penalizes payers who do not have a name/SSN that matches IRS records.

There are steps to take to correct TIN validation errors.  The first step is to double check the W-9 form and contact the employee.  Is the last name spelled correctly?  Is the SSN correct? Does the last name include hyphens (I have tried TIN matching with and without hyphens and have found that missing hyphens can cause a name to mismatch)?  Commas and periods are invalid characters of an individual or business name and eliminated before efiled. Did the person get married recently and has a new last name?  Go back to the employee or business you are working with and keep asking questions and we can run TIN matching to see if the name/TIN matches IRS records.

I remember TIN matching a business with the name ‘Greater Business Association’ and it did match IRS records.  We ran interactive TIN matching many times trying ‘Greater Business Association of Atlanta’ and ‘Greater Business Association of Georgia’ and many other variations of these names.  None matched!  Finally, we tried GBA (just the initials) and it matched which means that the initials is what the IRS has on record for that particular business.

I also remember TIN matching my brother’s name/SSN and it did not match IRS records. My own brother! I followed up and found out that he gave me the EIN for his local business instead of his SSN.  This is a common error.  Small business owners oftentimes use their business EIN and their name (which wont match IRS records) instead of their business name and EIN or individual name and SSN.

You have to make a good faith effort to correct TIN validation errors.  It takes time and the more mismatches you have, the more time you have to spend following up with employees, researching and TIN matching. But the time invested now will pay off.  The IRS always starts nice and tax year 2015 is the non-penalty year for ACA efilings.  But in time, the IRS will move away from niceness and the names and SSNs to match IRS records.

Tax year 2015 was the 1st year the 1095-B and/or 1095-C forms were required.  The IRS extended the due date for printing and mailing to March 31 and the deadline to efile to the end of June.

For tax year 2016, you must print and mail a copy to the employee by January 31, 2017.  If the IRS provides an extension, we will post it here and on our website.  You must efile by March 31, 2017.  The IRS most likely will provide an automatic 1-month extension giving you until the end of April to electronically file the 1095 forms.

No.

You need one transmitter control code or TCC number in order to efile any number of 1095-B and/or 1095-C forms.  You can efile for multiple employers using that one TCC number.

We are a service bureau and as such, we can efile on your behalf using our TCC number.  Email sales at info@1099fire.com or call sales at 480-460-9311 for more information on how we can efile 1095 forms on your behalf.

Our 1095 software contains 1095-B (and its 1094-B transmittal summary) and 1095-C (and its 1094-C transmittal summary) forms.  You order the software online at this link

https://www.1099fire.com/buy_now.htm

There are 2 versions:

1. Single-employer.  The single employer option is less expensive and lets you efile forms for one employer with multiple employees.  You will type in the employer EIN during registration and then the software will lock in that EIN for printing and electronic filing.
2. Enterprise.  The enterprise version lets you efile for multiple employer EINs and their respective employees.

You can also order by phone at (480) 460-9311.

A common comment is

The total number of employees auto populated does not match my employee count.

Our printers can print, fold, stuff and seal a fixed number of pages per envelope. We have it set to print, fold, stuff and seal one page per envelope. We cant our printers look ahead and include a continuation sheet if it exists when there are more than 6 covered individuals.  So if there are more than 6 covered individuals, the software puts the first 6 covered individuals on one 1095 form and the 7th through 12th on the next 1095 form.  The forms are printed and mailed separately.  While we can make the software do anything, our printers are more rigid.

The IRS released Notice 2016-70. The notice does two things.

• The notice gives employers additional time to print and mail the 1095-B and/or 1095-C forms to employees.

The due date was January 31, 2017 and is now March 2, 2017.  Employers must furnish the 1095 forms to the employees by March 2, 2017.  Paper copy of Form 1095 must be sent to the IRS by February 28, 2017 or file Form 1095 electronically to the IRS by March 31, 2017.

Last year, the IRS released Notice 2016-4 which extended the deadlines for furnishing the 1095 forms to individual taxpayers as well as filing the 2015 ACA forms to the IRS (both the paper and electronic filing deadlines were extended in 2015). Notice 2016-70 only extends the due date for providing the 2015 ACA forms to the employees.

• The notice “extends good-faith transition relief” for another year.

In tax year 2015, the IRS announced that they would not penalize employers for incorrect or incomplete forms if the employer made a good-faith effort to comply with the ACA reporting requirements.  This same good-faith effort is asked of employers in tax year 2016.  Specifically, employers that make a good-faith effort to comply with the ACA reporting requirements for 2016 are not subject to penalties under Code sections 6721 (penalties for late, incomplete, or incorrect filing with IRS) and section 6722 (penalties for late, incomplete, or incorrect furnishing of statement to individual taxpayers).

No, there is not a way at this time to delete accepted ACA transmissions.  You can efile a correction.

We are currently in tax year 2016. Many clients have approached us to efile tax year 2015 originals and corrections. This is more challenging then I originally expected but the process is easy in hindsight.  We called and emailed the IRS to attain the below steps and I have successfully efiled tax year 2015 data in tax year 2016.  The steps are:

1. Use tax year 2015 ACA software to generate the data file.  The header and body of the XML data file must match Schema 2015v8.0 for the form data file which is the last schema version the IRS released for tax year 2015.
2. Use tax year 2016 ACA software to generate the manifest file. But you need to make changes to the 2016 manifest file.
3. When your generate the manifest file, the software asks for ‘payment year’ and ‘are you efiling a prior year’.  Select payment year 2015 and yes that are efiling a prior year.
4. Remember to change the software IDs to reflect 2015.

Those are the steps.  If you have any problem efiling prior year ACA data, call or email us anytime.  We can efile on your behalf.

The key to coding section 16 is understanding that it is directly related to the codes that reside in section 14 (Offer of coverage).

If you use the code 1A in section 14 as your offer of coverage, you are reporting to the IRS that you are offering coverage that is affordable because it is under the federal poverty line.

• If the employee enrolls in coverage, the code is 1C.

• If the employee declines coverage, your safe harbor code in 16 is 2G. This explains to the IRS why your coverage is affordable and you are basing that affordability on the federal poverty line.

If you use the code 1B, 1C, 1D, or 1E, and

• they enroll in coverage your code in section 16 is 2C.

• If they do not enroll in coverage, you must enter the save harbor code in section 16 that applies to your company. This is an explanation to the government as to why your offer of coverage is affordable. The IRS safe harbor codes are listed below, followed by a summarized explanation of those codes.

IRS Safe Harbor Codes

2E – Multiemployer interim rule relief. Enter code 2E for any month for which the multiemployer arrangement interim guidance applies for that employee, regardless of whether any other code in Code Series 2 (including code 2C) might also apply. This relief is described under Offer of Health Coverage in the Definitions section of these instructions.

Note. Although ALE Members may use the section 4980H affordability safe harbors to determine affordability for purposes of the multiemployer arrangement interim guidance, an ALE Member eligible for the relief provided in the multiemployer arrangement interim guidance for a month for an employee should enter code 2E (multiemployer interim rule relief), and not codes 2F, 2G, or 2H (codes for section 4980H affordability safe harbors).

2F – Section 4980H affordability Form W-2 safe harbor. Enter code 2F if the ALE Member used the section 4980H Form W-2 safe harbor to determine affordability for purposes of section 4980H(b) for this employee for the year. If an ALE Member uses this safe harbor for an employee, it must be used for all months of the calendar year for which the employee is offered health coverage.

2G – Section 4980H affordability federal poverty line safe harbor. Enter code 2G if the ALE Member used the section 4980H federal poverty line safe harbor to determine affordability for purposes of section 4980H(b) for this employee for any month(s).

2H – Section 4980H affordability rate of pay safe harbor. Enter code 2H if the ALE Member used the section 4980H rate of pay safe harbor to determine affordability for purposes of section 4980H(b) for this employee for any month(s).

UNDERSTANDING SAFE HARBOR CODES

FEDERAL POVERTY LINE SAFE HARBOR – 2G

If an employer satisfies the requirements for this Safe Harbor, their insurance coverage offering will be considered affordable under the employer mandate.

Who should use the Federal Poverty Line Safe Harbor?

This safe harbor may be most useful for employers with seasonal employees and employers who use the look-back measurement period to determine if variable-hour or seasonal employees have full-time status.

How to use the Federal Poverty Line Safe Harbor

Take the Federal Poverty Line (FPL) for a household of one in the current plan year ($11,880 in 2016), and divide it by 12. If your employees are not paying more than 9.66% (for plan years beginning in 2016) or 9.56% (for plan years beginning in 2015) of the FPL for their health coverage premiums, your coverage is considered affordable under the employer mandate.

Disadvantages of Federal Poverty Line Safe Harbor

This method typically provides the lowest threshold allowed for monthly premiums. Other methods generally allow for a higher monthly premium.

W2 SAFE HARBOR – 2F

If an employer satisfies the requirements for this Safe Harbor, their insurance coverage offering will be considered affordable under the employer mandate.

Who should use the W2 Wages Safe Harbor?

This safe harbor may be most useful to an employer with full-time employees who regularly work 40 hours per week and whose compensation is unlikely to decrease during the year.

How to use the W2 Wages Safe Harbor

Refer to Box 1 of an employee’s current year W2 form. If the employee’s health coverage premium is not more than 9.66% (for plan years beginning in 2016) or 9.56% (for plan years beginning in 2015) of Box 1, your coverage is considered affordable under the employer mandate.

Disadvantages of W2 Wages Safe Harbor

This safe harbor counts only earned wages, and does not permit an employer to impute income that would have been earned had they not taken a leave of absence. Box 1 income does not include pre-tax contributions, which will reduce the maximum affordable amount; this must be calculated monthly for every employee in your company.

RATE OF PAY SAFE HARBOR – 2H

If an employer satisfies the requirements for this Safe Harbor, their insurance coverage offering will be considered affordable under the employer mandate.

Who should use the Rate of Pay Safe Harbor?

This safe harbor may be most useful for employers with hourly employees and the need for a fast, “failsafe” calculation method. If the Rate of Pay safe harbor is met for your lowest-paid employee, then it will also be met for all other employees.

How to use the Rate of Pay Safe Harbor

Multiply an hourly employee’s lowest pay rate during the calendar month by 130 hours. If the employee’s health coverage premium is not more than 9.66% (for plan years beginning in 2016) or 9.56% (for plan years beginning in 2015) of this amount, your coverage is considered affordable under the employer mandate.

Disadvantages of Rate of Pay Safe Harbor

You can only multiply the hourly pay rate by 130 hours per month, even if employees actually work more hours. If you have any employees who are paid purely on commission, you cannot select this safe harbor. You cannot use the rate of pay safe harbor for any salaried employee who experiences a pay reduction in any month.

IRS Forms 1095-C and 1095-B must be postmarked by January 31, 2018. The IRS gave companies a break with extended deadlines and leniency for good faith effort in prior years. But the tide has turned and the IRS has given no indication of extended deadlines or leniency for good faith efforts. If the IRS publishes any notices which extend the due dates for certain information reporting requirements for 2018, we will update this page immediately.

On November 1, 2017, Tax Year 2016 Forms will be considered a prior year return in AATS (Testing). When production opens in January, Tax Year 2016 Forms will be considered a prior year return in Production.  You can electronically file prior year originals and/or corrections and corrections are encouraged if you received ‘Accepted With Errors’.  However, putting together a prior year return is challenging.

To generate Tax Year 2016 or 2015 returns in AATS and Production use:

• Manifest file from Tax Year 2017 schema package
• Form Data File from Tax Year 2016 or 2015 schema package
• PaymentYr value “2016” or “2015”
• PriorYearDataInd value “1”
• Software Id for 2016 or 2015 (example, 2015 software Id’s start with 15XXXXXXXX)

We can help prepare and transmit current or prior year 1095 returns.  Just call sales at (480) 460-9311 with any questions.