What steps should an employer take in order to electronically file Section 6055 or Section 6056 information returns?

Author: Gloria Ju

Employers filing 250 or more information returns with the Internal Revenue Service (IRS) are required to file electronically using the Affordable Care Act Information Return System (AIR). According to IRS Publication 5164, Test Package for Electronic Filers of Affordable Care Act (ACA) Information Returns (AIR), and Publication 5165, Guide for Electronically Filing Affordable Care Act (ACA) Information Returns for Software Developers and Transmitters, an employer should:

  • Determine who will handle the electronic filing:
    • There must be a minimum of one responsible official, who has responsibility for the authority over the electronic filing of information returns for the firm or organization at one location. The responsible official is the first point of contact with the IRS, has the authority to sign the Application for Transmitter Control Code (TCC) and is responsible for ensuring requirements are adhered to; and
    • There must be a minimum of two and a maximum of 10 contacts, who may be responsible for transmitting and/or are available on a daily basis to answer inquiries from the IRS;
  • Register with e-services. Responsible officials and contacts must register and then log in within 28 days to confirm the registration after receiving a confirmation code;
  • File an Application for TCC. This is handled by a responsible official. An employer must complete the application if it performs one or more of the following roles:
    • Issuer: A business filing its own information returns. An issuer includes any person required to report coverage on Form 1095-B or any applicable large employer required to report coverage on Form 1095-C;
    • Software developer: An organization writing either origination or transmission software according to IRS specifications; and/or
    • Transmitter: A third party filing information returns to the IRS on behalf of any business; and
  • Conduct ACA Assurance Testing System (AATS) testing. Depending on the role(s) performed by the employer, different testing requirements apply. Software developers must pass AATS testing annually, while issuers and transmitters must do so the first year only.