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Handling compliance with the Affordable Care Act

marketing@points-north.com (Points North) — Fri, 26 Jun 2020 16:56:27 GMT

Staying HR Compliant in 2020

Once employers have familiarized themselves with the ACA obligations, they should also know of the penalties associated with non-compliance. Identifying and paying for full-time employees is fairly easy because of the straightforward details of their job but for variable hour employees’, it is not as simple. Some organizations make use of the ‘limiting’ strategy to manage such schedules but this strategy as its own set of problems. Problems such as workforce scheduling and variable labor requirements are factors that make this strategy impracticable. We’ve combined some of the best ways to ensure ACA compliance in this article and examined how ‘guidance’ can help you limit penalties.

Although the Affordable Act Care is applicable to qualifying employers in 2015, there are some members who are unable to afford insurance and can be penalized for non-compliance. To demonstrate how to minimize ACA penalty liability, we have used the example of a construction company owner.

For background, the ACA for Applicable Large Owners came into being in the year 2015. At that time, Applicable Large Owners of employers that have a full-time workforce of 100 people or more. In 2016, the threshold was reduced and an employer with at least 50 people working full-time was categorized as Applicable Large Employers. Some employers weren’t obliged to pay for insurance in 2015 qualified for it in 2016 after the threshold was revised and had to prepare accordingly.

The first step that an employer should take to ensure compliance is to manage the employee status. This will make the process to gauge which employees are eligible for insurance easier. Employers should have a time and attendance system in place apart from other calendar-based reporting requirements.

Although employers have had a number of years to understand what entails the reporting requirements of ACA, to what extent they are prepared is a question.

The 2014 ACA Study conducted the ADP Research Institute included data from over 800 HR and Benefits decision-makers in the US. The representative sample comprised of 403 HR supervisors, senior HR, and Benefits managers, executives of organizations with 50-999 employees and large organization with 1000 or more employees. How employee benefits, policies and systems are decided was studied with the resulting data’s reliability being at 95% confidence level for each category’s sample size.

Who is the key decision-maker in terms of ACA compliance?

New salary thresholds have taken effect as of January 1, 2020. Standard minimum salary levels for exempt employees (professional, administrative, and executive) have increased to $684 per week, from the current rate of $455 per week, or $35,568 annually. Additionally, the salary minimum for the highly compensated employee exemption is increasing as well, to $107,432 from the current $100,000. However, the exemption for certain computer employees who are paid hourly has remained the same, at $27.63 per hour.

Under these policies, up to 10% of these standard salary levels may be satisfied through non-discretionary bonuses and incentives, including commissions. Additionally, a special catch-up provision allows a payment of up to 10% of the minimum standard salary paid within one pay period after the 52-week period.

In order to maintain these employees' exempt status, these adjustments must be made effective January 1, 2020. HR professionals should identify impacted employees and make changes needed, keeping in mind that some states have their own salary thresholds that may be higher than the federal policies, and may apply different tests for these employees.

Salary History Bans

The key decision-maker of ACA compliance strategy is the Chief Executive Officer of the company. In 60% of the large employers, however, the decision is in the hands of the head of Human Resources. In short, solving ACA related challenges seems to be a team-effort and in most mid and large sized organization, people from various departments take part in ensuring ACA compliance.

Which employees are receiving healthcare coverage?

Most organizations are choosing to not limit the employee hours as per the service-hour requirements but also going beyond ACA full-time populations in terms of healthcare coverage.

These decisions are driven by the need to attract talent, some of the organizations are choosing to extend healthcare coverage to even those employees who don’t qualify as full-time. A quarter of midsized organizations are planning to limit the hours of some of its workforce in order to manage the ACA requirements.

Shifting Healthcare Costs to Employees

Employers are seen shifting the healthcare costs to their workforce as per the ADP RI study. 80% of the large organizations and 70% of midsized organizations have included the health care cost in the form of co-pays and similar deductions. The study also found that consumerism is being included in the health care cost through revised plan design. Consumerism exists in the form of Consumer-Driven Health Plans (CDHPs) and is meant to assist the employees in their health care buying decision.

Some employers have also introduced a low minimum value plan to comply with the ACA requirements. Having a CDHP with a 60% minimum value is going to streamline record-keeping and its reporting. It can also be helpful in minimizing the Excise Tax penalties. This penalty refers to a 40% tax which took effect in 2018 on health plans above a threshold. These health plans fall into the high-cost category of coverage. \

Addressing Affordability Requirements of the ACA

Affordability is one of the many challenges that employers face under the ACA requirements. According to the study, a considerable number of employers who cover healthcare benefits or are planning to do so in future are unsure about the affordability safe harbors they should be using for their workforce.

To address this concern, at least one plan offered to the employees should have a minimum of 60% value based on the employee cost of self-coverage.

How Employers Prepare for ACA Compliance

ACA compliance is an area of concern for most employers as per the ADP RI study. The ACA requirements are something that employers feel that they are not fully prepared to deal with. A primary reason behind this is the inability of organizations to gather timely and accurate data. It also stems from not having a system in place that can integrate information of employees such as payroll, benefits, time, and labor management. This information is important if you want to ensure ACA compliance.

Some employers do have access to all the data mentioned but aren’t confident about the accuracy of the information they have. Compiling and reporting are important components of healthcare-related information required by the Internal Revenue Service. The employers are also supposed to provide required notices to their workers, timely.

Although the information required for ACA compliance is detailed, the employers don’t need to put a load on their internal workforce and systems to gather and organize the data. There are a number of third-party organizations that employers can take onboard to do the job. These organizations are well versed in providing comprehensive ACA solutions such as certified expertise and dedicated service components.

Regardless of how an employer chooses to prepare for ACA reporting, it has to be done whether they do it on their own or involve a third-party.

Staying HR Compliant in 2020

marketing@points-north.com (Points North) — Tue, 14 Jan 2020 21:53:14 GMT

Staying HR Compliant in 2020

The new year brings new policies and regulations, so it's important to do a comprehensive review and update of your legal and HR compliance to make sure that you're on top of any new laws and regulations. Begin 2020 on the right foot, with the knowledge you'll need to answer any questions from corporate leadership, supervisors, and employees.

Here's what you need to know.

New Salary Thresholds for Exempt Employees under the Fair Labor Standards Act

Salary History Bans

Many states, counties, and cities have been prohibiting employers from demanding that applicants submit their wage history as part of the application process. There are also rules in place keeping employees from being able to retaliate against applicants who choose not to reveal their wage history. Most recently, Alabama and Illinois enacted laws that went into effect September 2019, while New Jersey and New York's laws banning employers from demanding this information became effective January 2020.

Keep in mind that each law or ordinance will have specific prohibitions, but given this growing trend, HR professionals should review their application requirements, as well as their protocols for interviews and the guidelines they provide recruiters.

Independent Contractor Status

It can be quite difficult to determine whether someone should be classified as an employee or an independent contractor. There are many different state and federal tests that are used, and they change at times. In 2019, the National Relations Relations Board established a test designed to be employer-friendly in SuperShuttle DFW, Inc., 367 NLRB No. 75 (Jan. 25, 2019).

Additionally, California recently recently enacted Assembly Bill 5, which severely restricts how an employer is able to classify someone as an independent contractor.

It's important for HR professionals to carefully check their independent contractors and make sure they're using the proper tests to determine the correct status for these individuals. They may need to change the status of certain independent contractors, classifying them as employees instead. HR professionals should plan their rollout of these changes if necessary, and make sure that they fully understand the consequences of any reclassification.

Medical and Recreational Marijuana

Another trend in the US is the legalization of medical and recreational marijuana. Ten states, along with the District of Columbia, have legalized recreational use, and effective January 1, 2020, Illinois has become the 11th. There are currently bills in other states that are pending.

This affects some employers' policies for drug testing. For example, at a local level, New York City will be banning employers from testing for THC or marijuana, effective May 10, 2020. Of course, marijuana use is still illegal under federal law.

Employers need to review their testing policies and keep an eye on any legal developments about drug testing. As legalization continues, employers' efforts should focus on prohibiting impairment on the job. This involves training for managers and supervisors to recognize symptoms of impairment and understanding the actions they should take. They should consider whether it continues to be appropriate to test for marijuana as a condition of employment.

Paid Sick Leave and Family and Medical Leave Laws

States, counties, and cities are increasingly passing laws enacting policies for paid leave. Some of these laws allow leave time to be used for any reason, while others require certain amounts of paid and sick leave, as well as family and medical leave. As these laws are passed it's important to keep up with them so that employees are getting the benefits that they are entitled to.

One example of paid leave laws is the one passed in Nevada and took effect January 1, 2020, which allows paid leave time to be used for any reason. Massachusetts has enacted a paid family and medical leave law, which has employer obligations that became effective October 1, 2019, with benefits that will become available to employees in January and July 2021. Other states and counties are modifying their existing laws to add benefits. New York is increasing paid benefits in 2020 and 2021, while California is expanding paid leave in 2021 to cover the needs of military families.

Data Management Is Key

Even as times change and policies evolve, the need for data remains constant. It's important to maintain your master data effectively so that you can easily implement any necessary changes to keep up with new policies.

The first step is ensuring that your master data is accurate, under control, and easily accessible. Before attempting to update any information to account for the new policies that are affecting your company, assess your data and make sure that everything is up to date and that all the necessary modifications are possible to implement correctly. While this is necessary for ensuring your compliance, it will also make it easier to manage all your HR tasks.

While technology is important, remember the human in Human Resources. It's important to maintain a balance between technology and people. So whatever your technological needs are, remember that you are using it to support people, and keep your focus where it needs to be.

Final Paycheck Compliance

Thu, 03 Oct 2019 12:33:45 GMT

Financial leaders should educate their HR counterparts of the importance of abiding by final payment rules.

Though federal rules from the Department of Labor (DOL) give employers some flexibility in determining when to issue final compensation to workers leaving an organization, final paycheck compliance laws differ from state to state, and those rules also change periodically. This can make it challenging for HR professionals in your organization to keep up with the regulations in order to avoid fines and penalties for violations of final paycheck rules.

Understand State Differences

The differences in state laws are complex. For example, California and Colorado generally require the final pay check be provided to employees immediately if terminated by the employer, while other states require that it is sent on the following payday. Rules can be different for employees who leave voluntarily rather than being terminated by the employer. And some states, like Florida, have no special rules regarding final paychecks.

These differences are just the start of the complexity. Some states have different rules depending on when the employee gave their notice. For example, in Hawaii, if an employee gave notice a pay period in advance, the final check is to be given to the employee on the last day of employment. Otherwise, the final check can be sent out on the next payday. Payment rules for unpaid vacation days differ from state to state.

Violations Can Result in Penalties and Fees

As an employer, violating a state's final paycheck rules can subject you to fines and legal expenses. In California, the penalty can be as much as 30 days of the employee's wages. In Illinois, the offending employer is subject to paying the back wages plus damages, an administrative fee, and a penalty paid to the employee based on the days the final payment was made. Many other states also base penalties on an employee's wages and the number of days that the final payment should've been made.

Beyond those costs, another issue with violating final payment rules is the negative sentiments of remaining employees. With social media, this sentiment rarely stays in-house for long. Once the information goes out to the public, there is reputational risk that your organization's potential customers and potential employees will hear about it. These headaches and expenses can be avoided.

How Who'sWhere Can Help

You can help to alleviate many concerns about final compensation by making sure your team is utilizing an integrated payroll and HR function system, contact us here for more information about this. This can help relieve some of these challenges by incorporating the laws and regulations regarding final paychecks and other payroll needs with terminations and termination procedures. Through this integrated system, you can offer more convenient and cost effective payment options to employees. Wisely Pay, for example, offers a paper check option and is not without cost, but is less expensive than the fines you may be subject to for noncompliance.

Of course, the benefits of this integrated system go well beyond compliance with final paycheck regulations. It further enables your business to have insight into the various elements of HR and payroll so you can use internal data to analyze expenses and budget as efficiently as possible. An integrated experience can help eliminate hidden costs of ownership associated with data upkeep; as well as speed up transactional processing in order to avoid penalties.

Financial leaders should educate their HR counterparts of the importance of abiding by final payment rules. A payroll system that is linked to your software can help ensure that final paychecks are issued in compliance with the law. Some organizations with multi-state operations may find it easier to use a service provider that has the HCM capabilities and know-how to address different rules and help keep the business in compliance. Find out more by contacting us here .

ACA Reporting Is Required and Strictly Enforced by IRS

Fri, 06 Sep 2019 12:53:56 GMT

As the fiscal year closes the employers have many queries regarding the status of the Affordable Care Act (ACA) Reporting. It is questioned every time the tax filing season looms. The answer to all these queries is that Yes! ACA is still the law and employers who tend to ignore their obligations towards ACA reporting can face some heavy penalties.

Employers Must Prepare and Report ACA Forms

Many employers have the misconception that requirements for ACA reporting are optional. The confusion is triggered by the current administration's ongoing efforts for repealing and replacing the ACA. A further misconception is caused by the Tax Cuts and Jobs Act has been passed in late 2017. This tax legislation modified the individual mandate which required individuals to have ACA compliant health coverage. It was done by removing the penalty for non-compliance. However, this doesn't come into effect until the end of 2019. And more importantly, the employer mandate still holds its standing. This means all affected employers must file 1095-C reporting forms and provide copies to employees before the deadlines assigned by the IRS. The most affected employers are those who have 50 or more full-time employees and hold the status of Applicable Large Employers (ALEs). According to the new Tax Act, ACA reporting for employers remains unchanged.

Stronger IRS Enforcement Efforts Underway

Although in the past IRS has been a little lenient with the ACA reporting violations but this won’t be the case anymore. IRS has finished working on a sophisticated system which is designed to enforce the rules and target the employers who don’t comply with the annual reporting requirements or employer shared responsibility payment.

The IRS first sends out Letter 5699 which states that the IRS believes that an employer was an ALE but ignored to provide the proper ACA information. It asks the employer for confirming the name used for filing. It also asks for the date the ACA information returns were submitted to the IRS and the Employer Identification Number (EIN). Then the IRS sends out Letter 226J for notifying the employers of any penalty assessments. Until now, more than 30,000 letters have been sent out and issuing of fines over $4 billion.

You must keep in mind that missing the deadlines for completing and filing the ACA forms can cost you almost $270 per return and an intentional disregard can cost you around $540 per return. Although you may file Form 8509 for filing with the IRS for a 30-day extension.

ACA Reporting Help Is Available

It is critical to stay on track with the increased penalties for non-compliance and due to the IRS strongly following through with the enforcement. If you are an employer and are facing difficulties regarding filing with IRS or if you can’t figure out where you should start then you

should consider seeking professional help. Who’s Where is a firm dedicated to helping employers regarding ACA Reporting and Payroll Data Aggregation . If you want to schedule a session for discussing a potential partnership of if you want to contact us then feel free to do so anytime.

How to file an EEO-1 report?

Thu, 29 Aug 2019 12:46:08 GMT

When your company starts growing it means more success but it also means more responsibility. Once your company grows beyond a certain point, the US government requires you to submit additional information regarding your company being an equal opportunity employer. One of these additional things is the EE0-1 report. It is a compliance survey which is mandated by the Equal Employment Opportunity Commission (EEOC). It is compulsory for employers meeting certain criteria. If this is your first time then you can use the following steps to file an EEO-1 report.

1. Determine whether you need to file an EEO-1 report

You need to file an EEO-1 report if,

There are 100 or more employees on your payroll.
There are less than 100 employees on your payroll but you are affiliated with, controlled or owned by a company with overall more than 100 employees.
You have a federal contract or subcontract worth more than $50,000 and there are 50 or more employees on your payroll.
You serve as a depository of government funds or you act as an issuing and paying agent for US Savings Bonds and you have 50 or more employees on your payroll.

2. Educate yourself about the basics of the EEO-1 report

Usually, 30th September is the annual deadline for submission of EEO-1 report. Sometimes there is an official extension or you can request a one-time 30-day extension. If you operate as one establishment and operate in a single location then you will fall under the “Single Establishment Employers” and you will be required to file a single EEO-1 report. If you operate in different locations and as more than one establishment then you will fall under the “Multi-establishment Employers” and you will have to file various EEO-1 reports.

3. Collect the data for your EEO-1 report

Usually, self-identification by employees is preferable for ensuring the accuracy of data. You need to set up a procedure for conducting this employee survey. This should give everyone sufficient time to respond. You need to ensure that self-identification forms are provided to the employees and that they are collected on time. The parent company or headquarters must collect all forms form the various establishments. The employers are allowed to complete the data on behalf of the employees in case they refuse to identify themselves.

4. Prepare and submit the EEO-1 report

The race and job classifications appear by default in the report. You must follow these guidelines while preparing. When you have collected self-identification data from the employees you can start listing them by race, gender, ethnicity, job category, and establishment. You should make sure that each employee appears only once in the EEO-1 report. Then you should double-check your data. You can use the EEO-1 online filing system or other EEOC approved methods for submitting your completed reports.

If you need to file an EEO-1 report but can’t figure out how to collect data properly and how to file it then you needn’t worry. You can reach out to Who's Where because we specialize in EEO reporting. We are hoping to hear from you soon.

Looking for a solution to data aggregation?

marketing@points-north.com (Points North) — Fri, 02 Aug 2019 12:21:47 GMT

It is important to choose a reliable and secure data aggregation solution which provides you with the best data. If you manage to get financial data which is cleaned and enriched then you can make accurate assessments of the financial situation of your customers. Following are some of the things which you should look for while choosing a solution to data aggregation .

1. Depth and Breadth of Data

Companies which provide financial services need to access data with a lot of breadth and depth. It is more efficient to use a data aggregation solution which can extract data from multiple sources rather than just drawing data from one or two sources. When using a data aggregation solution, you also get to analyze and clean your data. Hence, you get to share it as a single source.

2. Data Clarity

Data can be cleaned and garbled code can be converted into something easy to read and understand. This practice is known as transaction data enrichment. This data then allows us to do effective data analysis which can help us better understand our customers.

This enables us to provide our customers with more convenient information. Call center and fraud chain costs can be reduced by the clarified data. This can also help you in understanding the customer saving and spending preferences, the share of wallet, payment habits, and even what financial services are the right fit for certain customer groups.

3. Speed and Simplicity

Speed and simplicity are the key requirements for an effective data aggregation solution. Through reduced integration costs, simplified coding, and shorter production timelines these improve the developer experience. Since data requests are handled as a single event rather than a cluster of API calls, therefore, data is retrieved much more quickly. Therefore, this reduces abandonment rates and shortens the customer on boarding process.

4. Artificial Intelligence (AI) and Machine Learning

Sophisticated data analytics are also required by the financial service providers which require a robust AI group and data science to enable that. AI allows you to create a new class of services, products, and business models. It also allows you to offer perspective, personalized, and predictive solutions to customers. Machine learning and AI can also be used for helping compliance with fraud detection and/or regulations. Machine learning allows you to learn what is the meaning of certain transactions and deciphering is done on its own. Hence, data aggregation can be provided at scale. The AI becomes smarter as more data comes in and it becomes much faster and better. Hence, data can be delivered in a cleaner form at a faster pace for all your customers.

If you are looking for a smart and effective Data Aggregation Solution which meets all your requirements and needs then you should consider acquiring the services of Who’sWhere. If you want to schedule a meeting to discuss further details or contact us regarding any queries then feel free to do so anytime. We are hoping to hear from you soon.

Handling compliance with the Affordable Care Act

marketing@points-north.com (Points North) — Tue, 09 Jul 2019 13:24:51 GMT

If you're the one in charge for handling compliance with the Affordable Care Act (ACA) reporting and audits then read on; those who aren’t compliant will face penalties from the IRS. But, as with anything that requires forms and filing, demonstrating ACA compliance on paper is a complicated process.

And, for ACA reporting , employers may feel particularly overwhelmed by the process. The ongoing responsibilities of taxes are hard enough, given all the forms. But, in fact, staying compliant comes down to preparation and organization.

Step 1: Track employer-mandate requirements.

Once full-time employees are identified, the next step is to track and document compliance with employer-mandate requirements. In other words, is there proof that coverage was offered to all eligible full-time employees?

Keep track of the dates that coverage was offered to each employee and when employees may have waived that coverage. Review 1094 and 1095 instructions to be sure that all information needed is readily available. Establish a process to track and organize this information in one place throughout the year to make ACA compliance easier.

Step 2: Report the cost of employer-sponsored group health plans.

Employers must complete an additional step when preparing tax forms to be ACA-compliant. Employers are required to report the cost of employer-sponsored group health plans on box 12 of the W-2 form to show workers the total cost of their individual healthcare in relation to the specific plan they use.

However, there are some exceptions. Employers who provide retired or former employees with healthcare coverage, but do not provide them a W-2, do not need to create that document just to report the cost of coverage. In addition, employers who give out fewer than 250 W-2 forms are not required to report the cost of coverage.

When reporting the cost of coverage is required , remember to include the total cost -- both the company’s and the employee’s contributions.

Step 3: Identify full-time employees.

The first step in ACA compliance is to determine who is a full-time employee. In 2016, companies with 50 or more full-time or full-time equivalent employees must offer minimum essential coverage to at least 95 percent of these full-time employees. But, how are full-time and full-time equivalent employees determined? Does the company’s definition align with the regulations?

To get a total number of full-time equivalent employees, use the IRS formula. Add up the hours that non-full-time employees are paid during a year and divide the total by 2,080. The answer is the number of full-time equivalent employees.

To complete the formula accurately, use technology to better track employee hours. Employees don’t always fill out timesheets correctly: They often include errors -- especially when it comes to overtime and holiday hours. HR software can automatically track hours to better manage employees and stay ACA-compliant.

Step 4: Educate employees.

ACA compliance is confusing for employers, but it can seem even more complicated for employees unfamiliar with new laws and forms.

This year, employees will receive new 1095 tax forms from either their employer or their insurance carrier, and they need to know what to expect. Educate employees on these new forms: what information they will contain and the purpose of the form. Send them information to review before they receive the forms, and walk them through the process when the new forms arrive.

In addition to educating employees on new forms, employers also need to provide employees with the correct information about their benefits and coverage. Do employees need a summary plan description or a summary of benefits and coverage, and when do they need them? Review the requirements to provide employees with the right information at the right time.

When dealing with ACA, reporting may seem even more complicated and overwhelming. But, if you’re prepared and have the right information, the process doesn’t have to be so scary. Please reach out to us today to inquire about having Who's Where help you with this process.

Common IRS Error Codes

marketing@points-north.com (Points North) — Mon, 01 Jul 2019 20:32:22 GMT

In this blog and article we will be discussing and showing you Common IRS Error Codes.

Due to the complexity of the process, utilizing a reputable software vendor to file your 1094/1095 data electronically with the IRS is considered to be a best practice. One reason for this is that if it turns out that there’s a problem with some of your ACA data , the IRS doesn’t necessarily make it easy to figure out what went wrong. The best you will get as feedback from the agency is a series of cryptic error codes that you’ll have to decipher in order to discover the problems that they identified with your transmission.

What are IRS Error Codes and what you need to do about them?

Each IRS Error Code is related to a specific mistake or set of mistakes in your filing. In most of the cases, these can be corrected by making minor changes to your filing. For that, you need to make sure that you correctly interpret the IRS Error Codes and make changes accordingly. Sometimes this can consume a lot of time and can be quite difficult to execute if done in a conventional way. The best way to tackle these challenges is to consider investing in a smart and innovative solution for your e-filing.

What kind of e-filing you should invest in?

When considering a software vendor to handle your ACA e-filing, it’s a good idea to make sure that they’re knowledgeable about the IRS e-Filing process so they can identify and eliminate any errors before the forms are e-filed. They should also be able to translate the IRS error codes into actionable items for you to correct.

What are some of the common IRS Error Codes?

The table below includes some of the most common ACA IRS error codes and their explanations. Again, most of these should be handled by the software solution before the forms are e-filed to avoid corrections as well as outright filing rejections from the IRS.

These error codes from the IRS are anything but simple, and attempting to figure them out without the assistance of an ACA solution can be daunting. Utilizing a reputable software vendor that understands these error codes (as well as the many other errors that could potentially occur with e-filing) will take a whole lot of guesswork out of a very complex process.

I need a digital solution for IRS Error codes. Where should I go?

If your filing was rejected and you are struggling with understanding the IRS Error Codes assigned to your filing then you needn’t worry. You can acquire the services of Who’sWhere for helping you with the IRS Error Codes. We specialize in providing innovative solutions for ACA compliance . We can help you in correcting your e-filing according to the assigned IRS Error codes in an easier way. Feel free to reach out to us if you have any further queries.

Disclaimer: The information provided within is for general informational purposes only. It does not necessarily address all of your specific questions or issues. It should not be construed as, nor is it intended to provide, legal advice. Questions regarding specific issues and application of these rules to your 1095-C reporting should be addressed by your legal counsel.

What is Payroll Data Aggregation?

marketing@points-north.com (Points North) — Mon, 17 Jun 2019 22:29:48 GMT

Employers often have to face complex issues regarding employee withholding taxes. This gets even more challenging when employees on their payroll, earn a mix of regular and non- standard income.

The non-standard income is known as supplemental wages and there are very strict rules regarding if the employer or the head of payroll can combine both types of withholding into an aggregate amount. This aggregate amount is then used for calculating the final withholding tax owed by the contractor or the employer.

Payroll Data Basics

The Internal Revenue Service (IRS) categorizes employee wages as regular wages and supplemental wages. Regular wages are any amount paid through standard methods like hourly income or monthly salary. Every other kind of payment falls in the category of supplemental wages. It can be in the form of lump-sum, commissions, or advances.

Special payments covering vacations and illness are also categorized as supplemental wages. For this type of withholding, they can either opt for the aggregate method or a flat rate of 25%. In the aggregate method, the employers can pay taxes on both supplemental and regular wages at the rate specified for the regular wages.

Payroll Data Calculations

For calculating the withholding via the aggregate withholding method, the employer or the head of payroll needs to aggregate the payroll data. Then the tax rate for regular wages is used to calculate the total amount of withholding tax. The rate being used for this calculation is specified by the employee’s W-4 .

The head of payroll or the employer then subtracts any tax amount which was previously deducted as withholding from the regular wages. And the rest is subtracted from the supplemental wages.

Payroll Data Required Use

Sometimes it becomes necessary that employers use the aggregate method rather than the flat-rate method. This happens if the employer failed to deduct withholding tax from the employee’s regular wages in the last fiscal year. It also becomes necessary if the payroll department of the company doesn’t separate the supplemental and regular payments.

The utilization of the aggregate method also depends on whether the employee received the regular wages and supplemental wages as separate payments or they received them together.

Common Scenarios

The IRS has specified 9 common scenarios for reducing confusion and helping employers regarding the calculation of their withholding taxes in an easy and accurate way. If the employee receives only semimonthly advances against future commissions, monthly commissions, or irregular commissions exceeding $1000 then the head of payroll must use the aggregate method. And if the supplemental wages were given in the form of severance pay, termination payoff, signing bonuses, lump-sum, sick pay, or vacation pay then the employer and the head of payroll is free to choose between the flat-rate method and the aggregate method.

Payroll Data Aggregation can be a very challenging task especially if you have multiple payroll systems and locations. If you are facing problems regarding this and need professional help then you should contact Who’sWhere , a division of Points North . We specialize in providing innovative and smart solutions for ACA compliance, certified payroll compliance, and workforce reporting.

Are all employers required to e-File with the IRS?

marketing@points-north.com (Points North) — Fri, 31 May 2019 15:34:32 GMT

We are dedicated to helping our clients navigate the complexity of ACA and employee eligibility reporting . Below you will find information regarding whether or not all employers are required to e-File with the IRS.

There is a process provided by the IRS for electronically filing federal tax returns known as e-File. The e-File system includes a wide variety of ways to pay and e-file. However, this depends on the form type being filed.

There is a big difference between sending payments and filing forms. For example, E-file is used for filing forms. For making payments with your filing, you may or may not be able to use e-File. This again depends on the type of form being filed. If you want to make payments without filling any form then you can use the EFTPS system of the IRS. Take a look at some of the different services we can offer to help with here .

Tax Forms You Can E-File

There are many options for e-Filing of forms . For example:

Affordable Care Act (ACA) 1094-B and 1094-C and 1095-B and 1095-C forms can be e-filed.

Corporation and S corporation income tax returns can be filed by utilizing the modern e-File system.

Personal income tax returns can be filed as well. This includes Schedule K-1 for partners, LLC members, and S corporation owners. It also includes Schedule C for single-member LLCs and sole proprietors.

These can be filed by using the IRS FreeFile System.

Information returns which constitute 1099 forms can be filed as well. This includes 1099-MISC for the non-employees. It can be filed by utilizing the IRS FIRE (Filing Information Returns Electronically) System.

Business employment tax returns can also be filed. This includes payroll taxes for form 941 and unemployment taxes for form 940. These can be filed via the modern e-File system.

For making payments regarding employment tax you can use EFTPS system of IRS. Use taxes and Excise taxes may also be filed by utilizing the e-File system.

For Filing and Paying Employment Taxes

Form 941, Form 944, and Form 940 are employment tax forms that must be filed by utilizing the e-File program.

Which Employers need to e-file with IRS?

An employer must file electronically if they need to file 250 or more 1095 forms. This requirement of 250 or more forms is separately applicable for each type of filed forms (B series or C series). It is also separately applicable for corrected and original returns.

For instance, if an employer is filing 500 1095-B forms and 100 1095-C forms then that employer must file the 1095-B forms electronically. But the employer is free to choose whether to file 1095-C electronically or not. Similarly, if an employer has 150 1095-C forms to correct then the employer is free to choose whether to file them electronically or not because they fall under the 250 threshold.

But if the 1095-C forms to be corrected were 340 then they must be electronically filed. However, regardless of the total number of forms, the IRS encourages all employers to file electronically. View the FAQ section of our website for more information.

The Key Takeaway

If you are an employer and you need professional help regarding filing forms via the e-File system then Who's Where is the perfect solution for you. We specialize in providing innovative software solutions for ACA Reporting and Payroll Data Aggregation. This simplifies ACA Tracking and IRS Reporting while aggregating employee data from various payroll systems.

ACA Update – More Certainty for the Years Ahead

marketing@points-north.com (Points North) — Tue, 14 May 2019 21:02:47 GMT

The past few years have brought forth a great deal of uncertainty surrounding the Affordable Care Act. The topic of ‘repeal and replace’ was front and center during the 2016 presidential and congressional elections, and 2017 saw several attempts at repeal, none of which were ultimately successfully at scrapping the law in its entirety.

After the successful repeal of the ACA’s individual mandate in late 2017 (which did not change any of the existing 1094/1095 reporting requirements), talk of eliminating or modifying the law was placed on the back burner during the election year of 2018. When Republicans lost control of the House of Representatives but kept control of the Senate in November, it virtually assured that no major repeal efforts regarding the ACA would pass through both chambers of a now-divided Congress.

Both President Donald Trump and Senate Majority Leader Mitch McConnell confirmed as much in early April, stating that there would be no major comprehensive health care reform efforts pursued prior to the November 2020 elections, which will put both the White House and control of Congress up for grabs. With all of Washington virtually in agreement on the stability of the ACA for the first time since the 2016 election, employers subject to the law’s reporting requirements can now operate with increased certainty about their obligations for the next few years.

To read more about these recent developments, visit the links below:

https://thehill.com/policy/healthcare/436973-mcconnell-to-trump-were-not-repealing-and-replacing-obamacare

https://www.pbs.org/newshour/politics/trump-says-he-never-expected-health-care-vote-before-2020-election

Disclaimer: The information provided within is for general informational purposes only. It does not necessarily address all of your specific questions or issues. It should not be construed as, nor is it intended to provide, legal advice. Questions regarding specific issues and application of these rules to your 1095-C reporting should be addressed by your legal counsel.

What Do the ACA IRS E-Filing Statuses Mean?

marketing@points-north.com (Points North) — Tue, 14 May 2019 20:59:18 GMT

You’ve completed your IRS 1095-C forms for a tax year, submitted them with the 1094-C form to the IRS electronically through e-Filing, and have received a “status” response from the IRS. What does that status mean?
t’s important to note that if submissions were rejected due to formatting, employers should NOT mark the original submissions as corrected when resubmitting. Corrections only take place when you are changing actual data elements from your 1095 or 1094 forms, such as employee names, SSNs, etc.

Understanding the IRS e-Filing statuses is key to a successful ACA processing, and utilizing a reputable software vendor that’s familiar with them (and the data elements that lead to them) can help to make a confusing process far more simplistic.

Wondering about the strength of your passwords?

marketing@points-north.com (Points North) — Tue, 14 May 2019 20:53:45 GMT

In today’s world, it’s more important than ever to safeguard your online data in every way possible. News stories about hacking and data breaches are becoming all too common, with even major companies being regularly affected. A recent example is Marriott Hotels, who in November 2018 announced that they had discovered a massive data breach potentially involving as many as 500 million people.

So what can you do to make sure your online data is as safe and secure as possible? For many of us, reviewing the strength and quality of our passwords (or passphrases, as you will see below) is a great place to start.

National Institute of Standards and Technology (NIST) Guidance
The National Institute of Standards and Technology (NIST), is a branch of the Department of Commerce and provides technology, measurements, and standards to aide U.S. industrial competiveness in the world. Every few years, NIST issues guidance on how to create strong and secure passwords, and the latest recommendations call for using "passphrases" (a series of associated words) rather than traditional passwords. The three steps below illustrate how you can build a strong passphrase:

    Think about familiar items that have a relation to each other, such as items in your living room. Identify associated items that have meaning to you.
    Make sure the associations are very unique. Passphrases should be words that can easily go together in your head, but that no one else would ever suspect. As mentioned before, a good example would be the items in your living room (e.g., BlueCouchFlowerBamboo). A bad example would be the names of your children or relatives, since those associations can be easily discerned by others.
    Make the passphrase something that you can easily picture in your head; this will help you to recall the passphrase without needing to have it written down. The living room items example works here as well, as it is easy to picture your living room in your mind.

You can see how creating a passphrase rather than a traditional password can lead to a far more unique result, and the more unique a password is, the less likely that it will end up being figured out by someone who may have malicious intentions.

Key Elements to a Strong Password
If you decide that a passphrase isn’t for you and you prefer a more traditional password, NIST has guidance for those as well. Some of the key elements that NIST recommends for creating a strong, secure password include:

    A minimum of 8 characters and a maximum of 64 characters
    The use of special characters, such as exclamation points and asterisks
    Avoiding sequential and repetitive characters (e.g., 12345 or ZZZZ)
    Avoiding anything commonly used or easily guessable (e.g., P@ssw0rd)

Learn More about NIST and Cybersecurity
Keeping up with the latest security developments takes time and effort, and NIST is a great resource to utilize. To view their entire report on Digital Identity Guidelines, which contains more detail on the content in this blog, visit https://pages.nist.gov/800-63-3/sp800-63b.html. To learn more about NIST in general, visit their website at: https://www.nist.gov/

Need to Correct an IRS 1094-C or 1095-C Form?

marketing@points-north.com (Points North) — Tue, 14 May 2019 20:52:03 GMT

You’ve completed your reporting obligation for the Affordable Care Act. How do you know if you need to file a correction?

That depends on the error. There are errors that need to be submitted as corrections and others that do not require filing a correction. For this discussion, let’s assume there are errors that require corrections.

1094-C Corrections
The first thing to note is that a 1094-C is only marked as “Corrected” if there is an error on the 1094-C form itself. That means that a data element on the 1094-C was incorrect, such as the legal company name, not information on one of the accompanying 1095-C forms.

The 1094-C form is not considered a correction by the IRS if it is being submitted as the cover page for one or more corrected 1095-C forms. The accompanying 1094-C form is simply a new form and the data on it should reflect what is being submitted with it (e.g., if 1 form needs correcting, Line 18 on the 1094 form will state “1” even though hundreds of forms were submitted originally).

It’s important to note that if a submission was “Rejected” by the IRS, employers should NOT mark the original submissions as corrected when resubmitting. Corrections only take place when you are changing data elements on a form.

The table below describes the errors that must be corrected:

1095-C Corrections
Only 1095-C forms that have been filed with the IRS are considered “Corrected.” If you have furnished the 1095-C form to the recipient but have not filed the form with the IRS, the “Corrected” box should not be checked. Instead, simply write, type, or print “CORRECTED” on the new Form 1095-C and furnish it to the recipient. The form will be considered an original version when it is submitted to the IRS.

IMPORTANT: Enter an “X” in the “CORRECTED” checkbox only when correcting a Form 1095-C previously filed with the IRS.

If the 1095-C has been submitted to the IRS and an error is noted, the “Corrected” box at the top right must be checked in order to notify the IRS that the form has been updated and is being resubmitted as a correction.

The table below shows the types of corrections that must be submitted to the IRS:

When to Make Corrections
Quite simply, a corrected return should be filed as soon as possible after an error is discovered.

For additional information on filing corrections, visit the IRS site (irs.gov) or refer to the instructions at https://www.irs.gov/pub/irs-pdf/i109495c.pdf.

ACA Affordability Penalty

marketing@points-north.com (Points North) — Tue, 14 May 2019 20:48:27 GMT

There has been a lot of news the past couple of years regarding efforts to repeal the Patient Protection and Affordable Care Act, commonly referred to as the ACA. While the individual mandate was successfully repealed for 2019 and beyond (meaning that individuals who fail to have health insurance coverage will no longer have to pay a penalty), it’s critical for Applicable Large Employers (ALEs) to understand that the employer mandate is still in full effect for 2019 and beyond. That means that the penalties associated with not offering affordable coverage are also still in effect.

This blog will discuss the Affordability Penalty, which is one of the two penalties related to ACA, which provides that an ALE member may choose either to offer affordable minimum essential coverage that provides minimum value to its full-time employees (and their dependents) or potentially owe an Employer Shared Responsibility Payment (ESRP).

Potential ACA Penalties

An ALE member may be subject to one of two employer shared responsibility payments, but not both, and the two types of payments are calculated differently. An ALE member may not be subject to both types of payments regardless of the decisions it makes about offering or not offering minimum essential coverage to its full-time employees (and their dependents).

For either type of employer shared responsibility payment to apply to an ALE member, at least one full time employee must receive the premium tax credit for purchasing coverage through the Marketplace. In general, a full-time employee could receive the premium tax credit if:

    The minimum essential coverage offered was not affordable,
    The minimum essential coverage the employer offers to the employee does not provide minimum value, or
    The employee is not one of the at least 95 percent of full-time employees offered minimum essential coverage.

What Does Affordable Coverage Really Mean?

Under the ACA regulations, Applicable Large Employers (ALEs) must offer affordable health insurance to at least 95% of their eligible full-time employees. In the context of ACA regulations, “affordable” means that the cost the employee would pay if self-only coverage was elected cannot exceed a specified percentage of the employee’s household income. This percentage is adjusted each year. For 2019, the percentage is 9.86%.

It’s important to note that even if the employee selects a different coverage option (such as self + family), affordability is still based on the employee-paid portion for the offered self-only coverage providing Minimum Essential Value and Minimum Coverage.

Since employers are not likely to know the household income of their employees, there are three safe harbors that an employer may use to determine affordability for purposes of the employer shared responsibility provisions. In general, under these employer shared responsibility affordability safe harbors, instead of using household income to determine affordability, employers are allowed to use:

    Form W-2 Box 1 wages,
    An employee’s rate of pay (which is calculated differently for hourly vs non-hourly employees), or
    The federal poverty line for the tax year.

For more information about the safe harbors, follow this link to the IRS’s Question and Answer page and section 54.4980H-5 of the ESRP regulations.

What are the penalties for not offering affordable coverage?
An ALE member may be subject to one of two employer shared responsibility payments, but not both, and the two types of payments are calculated differently. For purposes of this blog, assume the ALE offered minimum essential coverage providing minimum value to 95% of its full-time employees (and their dependents).

Although expressed here as an annual number, the affordability employer shared responsibility payment is calculated on a monthly basis ($3,000/12 = $250 per month). The IRS will determine whether an ALE member owes this payment on a month-by-month basis. It is based on the number of full-time employees of the ALE member who receive the premium tax credit for purchasing coverage through the Marketplace because the coverage was not affordable.

On an annual basis, this payment is $3,000 (indexed for future years) for each full-time employee who receives the premium tax credit. The total payment in this instance cannot exceed the amount the employer would have owed had the employer not offered minimum essential coverage to at least 95 percent of its full-time employees (and their dependents).

The inflation adjustment beginning in calendar years after 2014 is increased based on the premium adjustment percentage (as defined in section 1302(c)(4) of the Affordable Care Act) for the year, rounded to the next lowest multiple of $10. As you can see, the adjustments to the $3,000 amounts have risen each year as follows:

    For calendar year 2015, adjusted to $3,120
    For calendar year 2016, adjusted to $3,240
    For calendar year 2017, adjusted to $3,390
    For calendar year 2018, adjusted to $3,480
    For calendar year 2019, adjusted to $3,750

The Bottom Line
As you can see, the employer penalties for not offering affordable health insurance coverage can be costly and should not be ignored. To collect these payments, the IRS has been sending out 226-J penalty notifications for tax years beginning with 2015, and it is the employer’s responsibility to provide documentation showing that the employee should not have received a subsidy (that affordable coverage was offered to the employee).

To avoid these costly penalties, employers should ensure that they are offering affordable qualifying coverage and take all of the ESRP regulations into account when developing employee health insurance plan cost offerings. calculator CTA

Do Dependents/Spouse Need to Be Reported on 1095-C Forms?

marketing@points-north.com (Points North) — Tue, 14 May 2019 20:46:20 GMT

Employees will oftentimes wonder why Part III of their 1095-C form doesn’t contain any information. This is because Part III of the form is used only to track individuals (employee, dependents, spouse, retirees, employees on continuation coverage, non-employees, etc.) covered under an employer-sponsored self-insured plan.

The instructional line for Part III that appears directly on the 1095 form is actually quite specific, stating: “If Employer provided self-insured coverage, check the box and enter the information for each individual enrolled in coverage, including the employee.” The full instructions for the 1095-C form get even more detailed, stating: “Complete Part III ONLY if the ALE Member offers employer-sponsored, self-insured health coverage in which the employee or other individual enrolled. For this purpose, employer-sponsored, self-insured health coverage does not include coverage under a multiemployer plan. Do not complete Part III if the ALE Member offers coverage only under an insured group health plan. If an ALE Member offers both insured and self-insured coverage, complete Part III only for employees who enroll in the self-insured coverage.”

So while it may seem like something is missing from your form if Part III is completely blank, remember that per the instructions, that section is intended to be left empty unless you’re reporting on employer-sponsor self-insured health coverage.

Eleven IRS Form 1095-C Code Combinations That Could Mean Potential Penalties

marketing@points-north.com (Points North) — Tue, 14 May 2019 20:43:15 GMT

The 1095-C form is used by employers with 50 or more full-time and full-time equivalent employees (also referred to as applicable large employers or ALEs) to report information required under Section 6056 of the Affordable Care Act. This includes their offers of health coverage and the employees’ enrollment in health coverage.

Part II (Lines 14-16) of the 1095-C provides information by month about the type of coverage that was offered, to whom it was offered, the cost to the employee for employee-only coverage, and any safe harbors or other relief that the employer reports. These lines are completed using a complex combination of indicator codes. These codes are required to be used in combination with not only each other, but also the employee’s full-time ACA status for each month and, in some cases, for the entire year.

There are currently 90 possible indicator code combinations for Lines 14 and 16, with just over half them being valid combinations (a code combination of 1H and 2C, for example, would be entirely invalid because 1H indicates that no offer was made, yet 2C indicates than an employee enrolled in coverage).

Valid Indicator Code Combinations that May Trigger a Penalty
While invalid code combination may result in a rejected form, there are some code combinations that could trigger an IRS penalty if the employee enrolls through the Marketplace.

There are 11 of these valid code combinations to watch for on your employee’s 1095-C forms. The chart below details these combinations:

While these indicator code combinations are valid, they may trigger a penalty if an employee enrolls for coverage through the Exchange. Check for any of these code combinations and make sure that the data that was used to determine them is accurate (e.g., coverage offered definition is correct, $ amount in Line 15 accurately shows the employee share of employee-only coverage—not necessarily what they enrolled in, etc.).

Also, always refer to the current year’s 1095-C instructions for the indicator code descriptions, as they may change from year to year. Here’s a link to the 2018 Instructions.

How to Get an ACA Reporting Extension

marketing@points-north.com (Points North) — Tue, 14 May 2019 20:39:15 GMT

Per the IRS, employers can get an automatic 30-day extension of time to file their ACA forms by completing Form 8809, Application for Extension of Time to File Information Returns. The form may be submitted on paper or through the IRS’s electronic system. No signature or explanation is required. Form 8809 must be filed on or before the due date of the returns in order to get the 30-day extension.

In addition, under certain hardship conditions, an employer may apply for an additional 30-day extension. See the instructions for Form 8809 for more information.

It’s important to note that the IRS has automatically extended the deadlines each year for furnishing 1095 forms to employees and has (but not consistently) extended the deadlines for filing the forms with the IRS. Make sure you understand which deadlines are extended before filing an 8809 Form. As a general rule, when the IRS has announced an automatic extension (as they have each year since 2015), the automatic extension using Form 8809 does not apply for that form for that year.

For example, for 2018, the date to furnish 1095 forms to employees was extended to March 4, 2019. The Notice indicates that the provisions under Treas. Reg. §§ 1.6055-1(g)(4)(i)(B)(1) and 301.6056-1(g)(1)(ii)(A) allowing the Service to grant an extension of time of up to 30 days to furnish Forms 1095-B and 1095-C will not apply to the extended due date.

However, for 2018 reporting, the Treasury and IRS have determined that there is no need for additional time for employers, insurers, and other providers of minimum essential coverage to file the 1095 and 1094 forms with the IRS. The Notice also does not affect the provisions regarding an automatic extension of time for filing information returns; the automatic extension remains available under the normal rules for employers and other coverage providers who submit a Form 8809 before the due date.

Information about Form 8809 as well as the form itself can be found at: https://www.irs.gov/forms-pubs/form-8809-application-for-extension-of-time-to-file-information-returns

5 Common ACA Reporting Errors

marketing@points-north.com (Points North) — Tue, 14 May 2019 20:36:49 GMT

Even though ACA reporting has been around for several years now, it’s still very common for mistakes to be made when completing the process. Here are 5 common ACA reporting errors that you should try to avoid:

1. Improperly Classifying Employees

    Classifying your employees as full-time, part-time, seasonal, and variable hour is critical to ensuring that they have the proper ACA statuses calculated for them based on the rules and regulations. For example, an employee who is hired and reasonably expected to work 30 or more hours every week must be classified as full-time for ACA purposes. While you may be used to using 40 or more hours a week as a minimum for considering an employee as full-time, the ACA standard is 30. Understanding and adhering to these classifications will help to ensure that you don’t missing offering someone coverage and submitting a form for them.

2. Using Invalid Indicator Code Combinations
    Part II (Lines 14-16) of the 1095-C provides information by month about the type of coverage that was offered to an employee as well as to whom it was offered, the cost to the employee for employee-only coverage, and any safe harbors or other relief that the employer reports. These lines are completed using a complex combination of indicator codes. These codes are required to be used in combination with not only each other, but also the employee’s full-time ACA status for each month and, in some cases, for the entire year. There are currently 90 possible indicator code combinations for Lines 14 and 16, with just over half them being valid combinations. For example, a code combination of 1H and 2C would be entirely invalid as 1H indicates that no offer of coverage was made, yet 2C indicates than an employee enrolled in coverage. Not having a solid understanding of the indicator codes and how they interact with each other can lead to creating erroneous forms, which can lead to increased scrutiny and potential penalties from the IRS.

3. Incorrectly Reporting Employees Who Work in Multiple Locations
    Employers are required to complete a 1095-C form for any employee that was considered full-time for any part of a calendar year. However, if an employee is working for two separate employers that are part of an Aggregated ALE Group (a group of ALE members that are treated as a single employer under sections 414(b), 414(c), 414(m), or 414(o) of the IRS code), then that employee’s hours must be aggregated to determine whether they were full-time. Furthermore, the employers that share the employee need to communicate with each other to determine which of them will report on that employee each month, as the employee should only be considered a full-time employee for the employer that they worked the greatest number of hours for during a month. Having an understanding of shared employees within an Aggregated ALE Group can help to make sure that filing mistakes for those employees are avoid.

4. Missing or incorrect employee addresses
    Employers will often furnish 1095-C forms to employees via the mail and only discover that they are missing addresses for their employees once the mailing deadline is upon them. It can also be the case that a mass mailing will take place, only to have forms returned to the sender due to incorrect mailing addresses. Taking time to review for any missing addresses as well as to verify the ones that you do have on file can pay off prior to the form furnishing deadline.

5. Incorrect EINs and Legal Names
    When your 1094-C/1095-C forms get filed with the IRS, one of the most common problems is a mismatch between the EIN and/or legal name that you submitted and what the IRS has on file. Making sure that you review the EINs and legal names that you plan to submit for misspellings, improper characters, etc., is usually time well spent when it comes to avoiding errors.

ACA Reporting Deadlines for the 2018 Tax Year

marketing@points-north.com (Points North) — Tue, 14 May 2019 20:33:11 GMT

The search for 2019 ACA reporting deadlines (filing for the tax year 2018) is over! The table below details the definitive deadlines for the upcoming round of reporting, sourced directly from the IRS following their announcement of the extension for furnishing 1095 forms to employees back in November 2018.

Note that for the 2018 tax year, the Treasury and the IRS have determined that there is no need for additional time for employers, insurers, and other providers of minimum essential coverage to file the 2018 Forms 1094-B, 1095-B, 1094-C, and 1095-C. Therefore, they did not extend the due date for filing Forms 1094-B, 1095-B, 1094-C, or 1095-C (see Notice 2018-94 at https://www.irs.gov/pub/irs-drop/n-18-94.pdf).