The 2023 ACA reporting season is officially behind us. Did your organization get everything into the IRS on time?
If you did, were all of your 1094-C and 1095-C submissions correct and accepted?
In 2024, it’s not enough to simply file your ACA information — it must also be accurate, as failing to submit correct filings can result in penalty assessments under IRC 6721/6722. These penalties may arrive in the form of Letter 5005-A or Letter 972CG.
In any case, you want to avoid them. Below, we discuss the various responses you can receive via the IRS AIRS portal upon completing your ACA submissions for any given tax year. But first, some background.
What Is the IRS AIRS Portal?
Short for Affordable Care Act Information Returns, the AIRS portal is the platform that organizations must use if they elect to electronically file their ACA details with the IRS.
The AIRS portal allows Applicable Large Employers (ALEs), insurance companies, and other entities to submit ACA-related forms electronically, including Forms 1094-C and 1095-C.
The 1094-C and 1095-C forms provide details about the health insurance coverage offered to employees and their dependents. These forms also play a key role in helping the IRS identify and enforce compliance with the ACA’s Employer Mandate, which requires ALEs to offer Minimum Essential Coverage that is affordable and meets Minimum Value to at least 95% of their full-time workforce and their dependents.
From a business perspective, the AIRS portal streamlines the process of reporting and complying with ACA regulations.
Six IRS ACA Filing Responses
Now, organizations that electronically file their ACA information through the AIRS portal may receive one of six responses after submitting their healthcare details for the year.
- Accepted: Getting an “Accepted” status after sending forms electronically is the best outcome. It means the IRS didn’t find any mistakes in the information you filed compared to what they and the Social Security Administration (SSA) have on file.
- Accepted with Errors: “Accepted with Errors” is the next best option to receive after submitting ACA filings through the portal. It essentially means the IRS found some disconnects in the information contained in the 1095-C forms transmitted and what it has on file. The most common issue involves Taxpayer Identification Numbers (TINs). For example, the last name of an employee may differ due to a recent marriage.
- Processing: When you see “Processing,” it means the IRS is still working on the submission. Check back later to allow the agency some time to process the information contained in the transmission.
- Partially Accepted: If you receive a “Partially Accepted” response, it means the IRS found some mistakes. This response requires attention as it’s possible that a large percentage of your ACA filings were rejected and could trigger penalties if not addressed. Double-check the information you submitted was in the correct format.
- Not Found: “Not Found” means the IRS couldn’t find the transmitter ID or Receipt ID used to file the information. It pays to have your ACA information transmitted via a trusted IRS-AIRS portal provider to ensure “Not Found” issues do not occur following an ACA submission.
- Rejected: “Rejected” is not an ideal response to receive after filing your ACA information with the IRS. It means your submission wasn’t in the right format or contained critical mistakes, such as having the wrong Employer Identification Number (EIN). If this happens, you’ll need to fix the errors and resubmit your entire filing again.
If your submission gets rejected, it’s still better than if you’d physically paper-mailed your filings. One of the many benefits of filing electronically is that you know almost immediately if your submission was accepted and done correctly due to the AIRS portal responses provided upon completion.
Conversely, if you paper-filed your ACA information, you wouldn’t know that anything was wrong until much later, increasing the likelihood of receiving a penalty substantially.
When to File ACA Corrections
As mentioned above, sometimes ACA filings are rejected due to formatting issues. If this is the case, it’s important to note what steps to take after receiving the notification. A common mistake we’ve seen organizations make is to mark their next submission as one with ACA corrections.
This is not the correct course of action as the filing is still an original submission. Instead, submit your filings the same as the first time, just ensure that the format is correct.
Organizations should only file ACA corrections if they are changing the details unique to the 1095-C forms, such as employee name, coverage effective period, social security number, etc. To submit these, check the box at the top right-hand corner of the 1095-C form. This tells the IRS that the information has been updated and is now being sent again as a “Corrected” transmittal.
When you’re filing corrected 1095-Cs, send them with a non-authoritative 1094-C transmittal. If you’re sending a corrected 1094-C, send it separately and mark it as authoritative.
If you’re sending both, they should be transmitted separately. You can indicate the type of 1094-C you’re sending by marking authoritative or non-authoritative on line 19.
Get Help with ACA Corrections
Completing ACA filings annually can be challenging, and submitting subsequent corrections can be even more difficult. If you need help, consider partnering with an ACA compliance expert that can help you navigate the filing and corrections process with ease.
Trusaic’s ACA Complete solution includes intuitive dashboards that outline successful filing details as well as items that require additional attention, such as TIN errors and formatting errors.
With a designated ACA account manager overseeing your efforts, you can rest assured that your fillings are being filed correctly and on time.
