By - November 14, 2017

Mr. Stevens Goes to Washington

Washington D.C. Skyline

Gil Stevens, Tango Health’s VP of Technical Operations, Security & Privacy Officer recently returned from Washington DC.  He was invited to the Information Reporting Program Advisory Committee (IRPAC) meeting. The IRPAC is a committee created to advise the IRS on information reporting and administration issues of mutual concern to the private sector and the federal government.  Membership meets 5 times a year to provide thoughtful perspectives and recommendations on many information reporting issues to help the IRS make the best decisions for taxpayers.

A wide range of topics were discussed during this meeting including relief extension for 1095-C forms, subsidies, filing constraints, and penalties.   Here’s a summary of the discussions we found most relevant:

Extension and Relief

Both the 30-day extension for 1095 print and “Good Faith” relief made it to the executive summary and were addressed by the current IRS Commissioner, John Koskinen. The Commissioner stated that relief has been given for 2 years and they are not sure how much more flexibility the IRS can give.  They took concerns from the panel and stated they will take the discussion under consideration when determining if an extension will be granted for an additional year.

Healthcare Subsidies

The IRS receives subsidy information for employees every month from every state.   And they still have many issues due to arrival times, format issues, and other factors. The IRS stated that the best case, would be an 18 month delay for getting out fine/penalty/tax notifications on ACA and most other IRS related topics.  However, the IRS ACA team is technically and administratively ready to issue ACA fines, penalties and tax notices, but has been held up as “not ready” by reticent members of the agency and leadership.

Filing Constraints

Members discussed many difficulties experienced with the ACA since inception. Some of those that we thought were interesting include:

  • Previous database was an old legacy and created in assembly language. The biggest dilemma with ACA is that the information would not fit in the existing record sizes, so they had transition to a whole new architecture and system. 
  • Difficulties in dealing with developers who speak in code and with lawyers who speak in articles. Trying to combine the two was a difficult task.

Penalties

The first priority of companies to be fined are those that didn’t submit, didn’t handle their rejections and provided substantially incorrect information according to the section of 6722. 

We take great pride in taking part in discussions such as those held at the IRPAC conference.  We feel it is imperative to stay abreast of all topics related to ACA compliance to provide our clients and prospective clients timely and relevant guidance and service.   The ability to advocate concerns on our clients’ behalf allows for meaningful policy changes and improvements and we are happy to participate.

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