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Regulation and Compliance > Federal Regulation > IRS

Why the 1095-C PPACA form launch could make you money

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Agents, brokers and other benefits advisors may sell insurance products and related products and services, but what you really do every day is help clients analyze, and protect themselves against, catastrophes. Early death. Disabling illnesses and injuries.

Acute conditions that could easily leave patients with $100,000 bills, and long-term conditions that could easily saddle patients with $500,000 bills.

Now, you can warn your benefits clients, and individual clients who help run midsize businesses, about Patient Protection and Affordable Care Act (PPACA) tax forms, including the 1095-C, the form an “applicable large employer” (ALE) is now supposed to use to describe the health benefits they offered employees.

Originally, employers were supposed to get the first wave of 1095-C forms to employees, and former employees, by Feb. 1. If employers were filing electronically, they had until March 31 to get copies of the forms to the Internal Revenue Service (IRS).

The IRS recently pushed the deadline for getting the forms to current and former employees back two months, to March 31, and the deadline for getting the forms to the IRS to June 30.

See also: IRS extends some PPACA reporting requirements for employers

That means ALEs have two more months to prepare to send out 1095-C’s, but that doesn’t mean all ALEs are ready.

Insurers have to send a similar form to enrollees: the 1095-B. One of the coverage providers required to send 1095-B’s is Medicare.

The process of sending 1095-B’s is so daunting that the Centers for Medicare & Medicare Services (CMS) decided, in November, to give Medicare managers permission to wait until the 2016 coverage year to come into full 1095-B form compliance.

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

The PPACA public exchange programs are supposed to send similar forms of their own, the 1095-A. The exchange program managers live and breathe PPACA. They are PPACA coverage warriors. But even they are facing barrages of government agency reports taking note of their problems with sending out accurate 1095-A’s in a timely fashion.

In other words: This stuff is hard even for government agencies that love PPACA.

What hope do your poor clients have? Their hope might be you.

For a look at three reasons that could be good for your revenue, read on.


1. Many employers are completely lost.

One interesting thing about the 1095-C advice opportunity is that even benefits professionals who simply know that 1095-C’s exist, and are important, may be ahead of the game.

ADP, a company that has used payroll services as a path into the benefits administration market, found in August when it surveyed benefits and human resources managers at 435 likely ALES — employers with 50 to 999 employees — that 43 percent had not heard of the 1095-C.

They were not able to answer any of the other questions about 1095-C preparedness because they had no idea what that meant.

To fill out accurate 1095-C’s, employers need month-by-month information about each employee’s health benefits.

Even at the midsize employers of ADP survey takers who knew what a 1095-C was, 10 percent were not really sure their companies had to file 1095-C’s, and 21 percent said their companies were not compiling monthly benefits data, or were not sure how to answer the question.

Benefits managers at ALEs that aren’t compiling the monthly health benefits information, or don’t understand that’s a big deal, may be the people who truly need a cold call from someone who knows what a 1095-C is.

See also: IRS posts major PPACA employer advice packet


2. Accountants, and non-accountant tax preparers, are not necessarily eager to hold clients’ hands.

Typical accountants and tax preparers probably know what a 1095-C is, but think of what a hash they often make of handling your individual clients’ (or your own) health savings accounts (HSAs.)

Why would you expect them to be any better at handling the confusing new 1095-C requirement than they are at helping HSA holders avoid getting little notes from the IRS about legitimate uses of HSA cash?

Some companies may be eager to offer employers 1095-C support tools and support services. (The fact that ADP published a survey report about this matter may be a clue that it’s interested in using 1095-C services to get prospects’ attention.)

But benefits specialists at Gallagher were reporting as long ago as October that they were already seeing what they regarded as the best, most comprehensive service providers reaching full capacity. 

Even for clients who know what a 1095-C is, being able to give them a list of suitable service providers that have the ability to take on more business may be helpful.

For clients who are unable to find support services, or unable to pay for them, pointing them to IRS websites explaining the basic nuts and bolts may be good enough, especially this year. The IRS has emphasized that it will look hard at whether employers did their best to meet the requirements when considering whether to issue penalties.

Even an employer that tries to estimate roughly what benefits it offered an employee each month, without succeeding at knowing exactly how to treat part-time temps who are eligible for both TRICARE, will probably be better off than an employer that simply ignores the form filing requirement because it’s too hard.

See also: The PPACA employee-counting time sponge

Corporate table

3. Chances are, you’re the advisor with the people skills. Maybe you can bring people to the table.

Unless you’re a tax preparer or an accountant as well as an insurance advisor, you can’t solve clients 1095-C problems yourself.

You should have probing discussions with your own compliance and errors and omissions advisors before getting involved, but this might be a chance for you to organize well-attended panel discussions featuring local benefits lawyers, accountants and crisis counselors. 

See also:

H&R Block earnings: Where are the PPACA tax claims?

New PPACA tax form drafts have a language all their own

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