Most companies today are aware of the requirements set forth by the Affordable Care Act. Employers with more than 50 full-time equivalent workers have to complete and submit forms 1094-C and 1095-C, while small businesses with less than 50 employees must finish 1094-B and 1095-B. Organizations were treated to an extended deadline for filing these forms in 2016. The IRS pushed the final date to May 31 if completed on paper, and June 30 if filled out electronically.
Employers may know they have these options, but it's possible they may not be completely familiar with the electronic option. Triton HR has all the details companies need to understand about the ACA Information Return System, or AIR:
The requirements
Any business filing forms 1094 and 1095 have the choice to utilize the IRS AIR system for submitting their documentation. However, any employer that needs to send 250 or more returns must file electronically. This obligation applies to each individual form. Companies are encouraged to file electronically even if they have less than 250 documents. Furthermore, every transmission is limited to 100MB. Any transfers over that maximum must be split in order to be sent via AIR.
Issuers vs. transmitters
The IRS uses different terms for the parties submitting ACA documentation through their AIR system. The definitions are as follows:
- Issuers: Providers of minimum essential coverage.
- Transmitters: Third-party partner who files returns on behalf of an issuer.
- Software developer: Party who will create programs for use in creating electronic files for AIR.

Designation of responsible officials
It's impossible for every executive or human resources representative to be involved in the ACA filing process. Companies need to specify who will be in charge of the procedure. These people have complete authority over documentation for the entire organization and should be available for potential IRS inquiries on a daily basis, if necessary, according to International Foundation of Employee Benefit Plans. Every application must include at least two contacts for responsible officials since this person will be the main point of interaction with the IRS.
Next steps for company leadership
Once businesses have specified the people acting as responsible officials, there are a few more actions they must take before beginning the electronic filing process. The IRS outlines those steps as such:
- Register to use IRS e-Services tools: To complete this registration, responsible officials must enter the confirmation code they received via U.S. Postal Service into the e-Services website within 28 days.
- Apply for an Information Return Transmitter Control Code (TCC): To utilize AIR services, companies must have a TCC, which will be visible online and sent via U.S. Postal Mail once application for a TCC is complete. Responsible officials will need to refer to their registration PIN to finish this signup. Every software developer, transmitter and issuer will receive a different TCC.
- Test communication with AIR: Every party submitting documentation must pass specific testing scenarios to ensure lines of interaction are viable for use.
Although the IRS AIR system was introduced in 2014 and is fairly new it is helping companies across the country streamline their ACA filing process. The electronic system makes the procedure more efficient, allowing business leaders to turn their focus to more important responsibilities. Although the steps necessary to register for the e-Services may seem long, they are worth the work in the long run for employers. Correct and timely filing of ACA documentation ensures organizations aren't met with costly penalties and unhappy workers.