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Lockton: IRS survey may hint at PPACA employer reporting delay

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Officials at the Internal Revenue Service (IRS) might be thinking about postponing the Patient Protection and Affordable Care Act (PPACA) employer coverage reporting requirement, or providing some other kind of temporary relief.

Ed Fensholt, compliance services director at Lockton Companies, has given that assessment in a commentary on a survey form that has popped up for at least some IRS website visitors.

Through the Foresee survey form, the IRS asks visitors about their satisfaction with the Affordable Care Act Information Returns (AIR) Program on the IRS website.

Some survey respondents saw a question asking them to “rate how ready your organization is to fulfill the requirements for transmitting information returns (Forms 1094-C, 1095-C) to the IRS,” Fensholt writes.

Employers are supposed to send file 1095-C forms to employees by Jan. 31, 2016, and to file the forms with the IRS by March 31, to tell the IRS and employees about the coverage the employees were offered in 2015. Employers are supposed to use the 1094-C transmittal form to summarize the contents of the 1095-C forms.

See also: The PPACA employee-counting time sponge

Filers can get one extension without providing a reason, and a second extension if the provide a reason.

The response options include “Not at all ready,” “partially ready” and “completely ready,” in addition to “don’t know,” Fensholt says.

Respondents can also give a short, free-form answer to a question about what the IRS could do to help them comply with the PPACA reporting requirements.

Fensholt says employers and reporting vendors should consider asking the IRS to give them more time to comply.

The Centers for Medicare & Medicaid Services (CMS) has already given the Medicare program more time to come into full compliance with a similar 1095-B insurer coverage reporting requirement.

See also: PPACA Form 1095-B: CMS to put off full Medicare compliance

The IRS may face pressure to enforce the 1095-C requirements for the 2015 coverage year, because of concerns that lack of employer reporting data contributed to problems with verifying exchange plan users’ coverage applications and tax returns for the 2014 coverage year, but the agency could also offer access to additional extensions or other types of relief, such as relaxation of the standards for the forms that employers do send out.