ACA Reporting Advisor

Welcome to MSEC’s weekly ACA FAQ on reporting. While details on how to complete IRS forms 1094 and 1095 (such as what codes to use on specific lines of the form) will not be covered, general questions on reporting requirements will be answered. For detailed information on form completion, contact your tax advisor, payroll company, or insurance carrier. If you have a general ACA reporting question, email it to aca@msec.org. The most commonly asked questions will be answered in this forum. In addition, the Health Care Reform Learning Zone, found on the MSEC website (msec.org), is a rich source of information about the Affordable Care Act (ACA).

Q: I’ve had a 1095-C form returned as “undeliverable.” What do I do with it now?

Requirements to furnish the 1095-C are met “if the form is properly addressed and mailed on or before the due date” (per IRS instructions). If the form is mailed, “the statement must be sent to the employee’s last known permanent address, or if no permanent address is known, to the employee’s temporary address.”

If the employee still works with your organization, deliver the returned statement by hand or get a new mailing address for the statement. If the employee has terminated and you’re unable to get an updated address, keep the returned statement (and its envelope) in your files as documentation of your attempt to provide the information. If the individual asks for the statement at a later date, you can provide it.

The IRS instructions don’t provide details on retaining returned statements, so following the guidelines for undeliverable W-2s is suggested. Those instructions direct employers to “keep for four years any employee copies of Form W-2 that you tried to but could not deliver.”

If you provided employees with 1095-Cs electronically, and the electronic form is returned as undeliverable, try to obtain a new electronic address from your records or the recipient. If you are unable to get a new electronic address, you must furnish the notice by regular mail or in person within 30 days after the electronic notice is returned.