Issue
CBIZ’s National ACA Compliance Consulting Practice first assisted this client in 2017 with the resolution of a proposed Employer Shared Responsibility penalty (ESRP), indicating that Minimum Essential Coverage was not offered to at least 95% of full-time employees for the 2015 reporting year — also known as the dreaded 226-J letter. The client continued to receive additional 226-J letters for past reporting years, each of which our team resolved. To prevent this from happening again, CBIZ conducted a thorough review of relevant data to identify key issues and help avoid future penalties.
Solution
- Our team met with the client and their ACA reporting vendor team to review data points and related outputs creating MEC issues.
- From those meetings, we identified issues with their e-filing process, which did not check the Authoritative Transmittal on the 1094-C. This was causing forms to show NO instead of YES for offering of MEC. We also uncovered erroneous offerings of coverage to non-full-time employees.
- Our team continues to review all 1094/1095-Cs issued by the client prior to the forms being sent out to employees. We also now handle e-filing with the IRS to cut down on individual errors on forms.
Outcome
- We have eliminated more than $97M in ESRPs for the client since 2017.
- The client now has our ACA Compliance Consulting team on retainer to review all forms, identify issues prior to reporting, suggest changes to programming, and check filings before e-filing with the IRS.
| Company Information | |
|---|---|
| Industry | Health, Fitness & Wellness |
| Geographic Footprint | National |
| Number of Employees | 19,000 |
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