Overview of ACA Reporting Requirements
Under the Affordable Care Act (ACA), certain organizations must report information to the IRS and individuals about health insurance coverage. The reporting requirements apply to:
- Insurance companies
- Self-insured companies
- Applicable large employers
- Employers that provide health insurance to their employees
ACA information returns and transmittals are electronically filed through the ACA Information Return (AIR) system.
ACA Assurance Testing System (AATS)
The ACA Assurance Testing System (AATS) opens on November 7 for tax year 2016 testing. AATS is a process to test software and electronic transmissions prior to accepting software developers, transmitters, and issuers into the AIR program.
Key Notes:
- Software developers – including employers and issuers – who passed AATS for tax year 2015 will not need to retest for tax year 2016; their tax year software packages will be moved into production status.
- New participants must comply with test requirements for tax year 2016.
Other Filing Systems
Other non-ACA information returns – such as Forms 1099 – can be electronically transmitted through the Filing Information Returns Electronically (FIRE) system.
Even if you previously used FIRE, if you are transmitting to AIR, you should familiarize yourself with the AIR procedures, which are different from those for FIRE.
Electronic Filing Requirements
If you are required to file 250 or more information returns, you must file them electronically.
Important Notes:
- This requirement applies separately for each type of return and separately to each type of corrected return.
- All filers are encouraged to electronically file even if filing fewer than 250 returns.
Resources on IRS.gov/AIR
IRS.gov/AIR provides a range of tools and resources to help you navigate the AIR system:
Publications:
- Publication 5164
Test Package for Electronic Filers of Affordable Care Act Information Returns – recently updated for processing year 2017. - Publication 5165
Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters – recently updated for processing year 2017.
Additional Resources:
- AIR webinars and presentations
Frequently Asked Questions
Who is required to file ACA information returns?
Under the ACA, insurance companies, self-insured employers, applicable large employers (ALEs), and any employers offering health insurance must file ACA information returns with the IRS and furnish statements to individuals regarding health coverage.
What is the ACA Assurance Testing System (AATS)?
The ACA Assurance Testing System (AATS) is a required process for new software developers, transmitters, and issuers to test their electronic filing systems before being accepted into the IRS’s ACA Information Return (AIR) program. It ensures compliance and proper functionality of ACA data submissions.
Can I use the FIRE system to file ACA forms?
No. The FIRE system is designated for non-ACA information returns like Forms 1099. ACA forms must be transmitted through the AIR system, which follows different procedures and requirements.
Is electronic filing mandatory for all ACA returns?
Electronic filing is mandatory if you are submitting 250 or more information returns of any single type. However, the IRS encourages all filers, regardless of volume, to submit electronically to streamline processing.
Where can I find resources to help with AIR system filing?
The IRS provides various publications and guides at IRS.gov/AIR, including updated versions of Publication 5164 (Test Package) and Publication 5165 (Electronic Filing Guide). Additionally, the site offers webinars and presentations for in-depth guidance.