2015 Form 1095-C Reporting: IT Vendor Survey

Balch & Bingham LLP
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On August 18, 2014, we posted our, “First Look at ACA Employer Compliance Software.” It’s time for an update. We invited less than a dozen vendors to answer these twenty-two questions.

With respect to each 2015 ALE coverage offer reporting service described below, what are your deadlines for –

Delivering an executed, written contract?

Completing all required system configurations?

Loading all required data (to date)?

Testing?

Have you completed all IRS AIR system requirements to provide the promised services?

Do you offer full-time employee status tracking?  Do you offer the IT tool only as part of consulting services or do you offer it off-the-shelf?

Do you offer auto-generation of Forms 1094-B, 1094-C, 1095-B and 1095-C?

Do you offer electronic delivery of Forms 1095-C to employees?

Do you offer to upload to the IRS, through the AIR system, Forms 1094-B, 1094-C, 1095-B and 1095-C?

Is your IT tool Oracle Solaris-based? Has it some other commercially available backbone? Or is it entirely proprietary?  Is there any commonly-used payroll or HRIS system from which your IT tool cannot currently import needed data?

What is your web page URL?

Do you offer online, live system demonstrations?  What is the contact information for arranging a live system demonstration?

Do you offer benefit plan consulting or brokerage services?  If so, are your ACA IT tools and assistance offered without your consulting and brokerage services?  Do you offer open group health plan enrollment assistance?

Do you offer payroll processing services?  If so, are your ACA IT tools and assistance offered without your payroll processing services?

We gave publication priority to Balch clients but promised coverage neutrality to all. We do not recommend any covered vendor over any other covered vendor, nor do we suggest that omitted vendors offer inferior tools, services, or value. We simply report selected vendors’ responses to our questions. We selected (in alpha order): ACA-GPS, Acuity Group, Alliance Payroll, Arc Technologies, and Five Points ICT. First, we publish each vendor’s entire set of responses, with most questions and some answers abbreviated. Then, a concluding table compares all “Yes” and “No” responses.

One more prefatory note: We asked two disqualifier questions. All five covered vendors are still taking new customers – a big plus; ask around.  And, all admit that they are still working toward full compliance with IRS AIR system registration, training and testing requirements. No fully-informed, fully honest vendor can say more. Form 4423, “Application for Filing Affordable Care Act (ACA) Information Returns,” was released after our vendor response deadline.

ACA-GPS

All deadlines: We anticipate price increases but have no deadline for new subscriptions.

IRS AIR system requirement completion: All applications have been completed and we have received our TCC number as both a software developer and transmitter. We have completed preparation of all required test transmissions and are currently testing.

Full-time employee status tracking?  Yes. IT tool only as part of consulting services or off-the-shelf? We sell the ACA Management Tool® as a web-based software subscription. We do not offer consulting services.

Auto-generation of Forms 1094-B, 1094-C, 1095-B and 1095-C? Yes.

Electronic delivery of Forms 1095-C to employees? Yes.

Do you upload to the IRS? Yes.

Is your IT backbone commercially available or proprietary?  It is built on an open-source framework. The code built on top of the open-source framework is proprietary. Is there any commonly-used payroll or HRIS system from which your IT tool cannot currently import needed data? We can import data from any system providing that it allows the subscriber to export the data into a xls, xlsx, or csv format.

Web page: www.acagps.com

Contact information for live system demonstration: We offer 3 options for viewing demonstrations of the ACA Management Tool®. A six minute demonstration video is available for viewing at: http://acagps.com/aca-management-tool-demo/. Live webinars are scheduled 3 times per week (all times Eastern): 10 am Tues.; 1 pm Wed.; 4 pm Thurs. Webinar registration link: https://attendee.gotowebinar.com/rt/6761762682530632706. For one-on-One Demonstration, contact Trish Moynihan, Director of Sales & Marketing, via email: trish.moynihan@acagps.com.

Benefit plan consulting or brokerage services?  Enrollment assistance? No.

Payroll processing services? No.

Acuity Group

Deadline for delivering an executed, written contract: October 1, 2015.

Deadline for completing all required system configurations: November 15, 2015.

Deadline for loading all required data (to date): To be determined.

Deadline for testing: To be determined.

IRS AIR system requirement completion: All required to date.

Full-time employee status tracking?  Yes. IT tool only as part of consulting services or off-the-shelf? Packaged with services.

Auto-generation of Forms 1094-B, 1094-C, 1095-B and 1095-C? Yes.

Electronic delivery of Forms 1095-C to employees? Yes, but still developing the employee election process.

Do you upload to the IRS? Yes, through our partner, Navigate HR.

Is your IT backbone commercially available or proprietary?  Proprietary. Is there any commonly-used payroll or HRIS system from which your IT tool cannot currently import needed data? We have not encountered a payroll or HRIS system from which we cannot import data.

Web page:  www.acuity-grp.com

Contact information for live system demonstration: jstarling@acuity-grp.com

Benefit plan consulting or brokerage services?  Yes. Enrollment assistance? Yes.

Payroll processing services? No.

Alliance Payroll

Deadline for delivering an executed, written contract: No written contract required.

Deadline for completing all required system configurations: November 1, 2015

Deadline for loading all required data (to date): November 1, 2015

Deadline for testing: November 1, 2015

IRS AIR system requirement completion: In progress.

Full-time employee status tracking?  Yes. IT tool only as part of consulting services or off-the-shelf?  No benefit plan consulting services offered. We offer our ACA tools only with our payroll processing services.

Auto-generation of Forms 1094-B, 1094-C, 1095-B and 1095-C? Forms 1094-C and 1095-C only.

Electronic delivery of Forms 1095-C to employees? Yes.

Do you upload to the IRS? Only Forms 1094-C and 1095-C.

Is your IT backbone commercially available or proprietary?  Proprietary. Is there any commonly-used payroll or HRIS system from which your IT tool cannot currently import needed data? None that we are aware of.

Web page: WWW.HRALLIANCE.NET

Contact information for live system demonstration: SALES@ALLIANCEPAYROLL.COM

Benefit plan consulting or brokerage services?  Enrollment assistance? No.

Payroll processing services? Yes.

Arc Technologies

Deadline for delivering an executed, written contract: September 15, 2015

Deadline for completing all required system configurations:  October 1, 2015

Deadline for loading all required data (to date):  October 15, 2015

Deadline for testing:  October 1, part of the system configuration.

IRS AIR system requirement completion:  No, currently finishing up and testing process.  We will have it completed by October 1, 2015 for our customers January, 2016 submission deadline.

Full-time employee status tracking?  Yes. IT tool only as part of consulting services or off-the-shelf?  We offer full-time employee status tracking, as part of our overall HRIS platform, Eight, that is provided as a SaaS.  Our ACA tracking and reporting capabilities are part of our overall on-boarding, employee compliance platform; and not a stand-alone solution.  It is not an off-the-shelf solution.

Auto-generation of Forms 1094-B, 1094-C, 1095-B and 1095-C? Yes.

Electronic delivery of Forms 1095-C to employees? Yes.

Do you upload to the IRS? No, we provide the file, but require our customers to upload/deliver the file to the IRS themselves.

Is your IT backbone commercially available or proprietary?  Is there any commonly-used payroll or HRIS system from which your IT tool cannot currently import needed data?  We utilize a SQL database.  Eight is a proprietary solution that utilizes the Internet for access.  We have yet to come across a payroll system that cannot provide us the data required to be imported into our platform.

Web page:  EightHR.com

Contact information for live system demonstration: We offer online demonstration.  Contact us by calling 601.991.1160, or emailing us at contact@afullcirclesolution.com.

Benefit plan consulting or brokerage services?  Enrollment assistance? No.

Payroll processing services?  No.

Five Points

Deadline for delivering an executed, written contract: November 1, 2015 (status tracking), December 1, 2015 (coverage offer reporting and electronic notice delivery).

Deadline for completing all required system configurations: November 30, 2015 (status tracking), December 15, 2105 (coverage offer reporting), December 31, 2015 (electronic notice delivery).

Deadline for loading all required data (to date):  Customer responsibility promptly after configuration.

Deadline for testing: Customer responsibility promptly after data loading.

IRS AIR system requirement completion: In progress and up to date.

Full-time employee status tracking? Yes. IT tool only as part of consulting services or off-the-shelf?  May be purchased with or without consulting services.

Auto-generation of Forms 1094-B, 1094-C, 1095-B and 1095-C? We allow employers to track all information needed to complete Forms 1094-C and 1095-C and transmit these forms to the IRS.  Once the final instructions and Forms 1094-C and 1095-C for the 2015 Tax Year are released we plan to add functionality to help automate completion of employee counts on Form 1094-C and Lines 14 through 16 of Form 1095-C.

Electronic delivery of Forms 1095-C to employees? Yes, the application will capture and store each individual’s consent to receive electronic delivery, electronically deliver Form 1095-C to those who have consented, and allow administrators to track hand-delivery or mail-delivery to individuals who did not consent to electronic delivery.  The system will allow for the generation of a batch file for the employer to print Forms 1095-C for any individuals that did not consent to electronic delivery.  We also plan to offer a printing service, where the employer can notify us that they are ready to print their Forms 1095-C and we will print them for delivery to individuals. 

Do you upload to the IRS? We currently offer transmittal of Forms 1094-C and 1095-C to the IRS via the AIR system for the 2015 Tax Year.  We are also evaluating the possibility of offering transmittal of Forms 1094-B and 1095-B in the future.

Is your IT backbone commercially available or proprietary?  Is there any commonly-used payroll or HRIS system from which your IT tool cannot currently import needed data? Our completely proprietary system uses data imported from third party systems (e.g., payroll, HRIS, carrier data, etc.) into our apps using our .CSV file formats.

Web page: www.fivepointsict.com

Contact information for live system demonstration: Please email info@fivepointsict.com.

Benefit plan consulting or brokerage services?  Enrollment assistance? Yes, with or without our IT tools.

Payroll processing services? No.

Table of Y/N Responses

Question

Vendor

Yes

No

IRS AIR System testing completed?

ACA-GPS

 

N

 

Acuity Group

 

N

 

Alliance Payroll

 

N

 

Arc Technologies

 

N

 

Five Points ICT

 

N

Full-time employee tracking?

ACA-GPS

Y

 
 

Acuity Group

Y

 
 

Alliance Payroll

Y

 
 

Arc Technologies

Y

 
 

Five Points ICT

Y

 

Auto-generation of Forms?

ACA-GPS

Y

 
 

Acuity Group

Y

 

             Only “C” Forms

Alliance Payroll

Y

 
 

Arc Technologies

Y

 

             Only “C” Forms

Five Points ICT

Y

 

Electronic delivery to employees?

ACA-GPS

Y

 
 

Acuity Group

Y

 

             Only 1095-C

Alliance Payroll

Y

 
 

Arc Technologies

Y

 

             Only 1095-C

Five Points ICT

Y

 

Upload to IRS?

ACA-GPS

Y

 

           through Navigate HR

Acuity Group

Y

 

             Only “C” Forms

Alliance Payroll

Y

 
 

Arc Technologies

 

N

             Only “C” Forms

Five Points ICT

Y

 

Benefit plan consulting?

ACA-GPS

 

N

 

Acuity Group

Y

 
 

Alliance Payroll

 

N

 

Arc Technologies

 

N

 

Five Points ICT

Y

 

Payroll processing?

ACA-GPS

 

N

 

Acuity Group

 

N

 

Alliance Payroll

Y

 
 

Arc Technologies

 

N

 

Five Points ICT

 

N

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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