As 2016 approaches, the IRS is issuing more detailed guidance on how employers will need to comply with the upcoming ACA information reporting requirements. As a reminder, the ACA information reporting rules require employers to report certain information about their employersponsored group health coverage both to participants and the IRS starting in early 2016. Any employer who is preparing 250 or more information returns must file those returns electronically with the IRS using its new ACA Information Returns system, also referred to as the “AIR” system, by March 31, 2016. The IRS recently updated its AIR Submission Composition and Reference Guide, which gives details on the IT requirements that employers will need to be aware of as they begin this process.

The AIR system requirements are complicated and permit employers to use a third party vendor to file these statements electronically with the IRS on the employer’s behalf. The end of the year is approaching quickly, and it is important for employers to begin to consider whether their own IT professionals will file information returns electronically with the IRS or rely on their payroll provider or other outside vendor to do this on their behalf. Any entity that plans on filing ACA information returns without assistance from an outside vendor will need designate a responsible official and additional contacts at their organization (typically IT professionals) and take steps to register with IRS e-services. This process can take up to a month so it is important that this registration occur in advance of January 2016. Now is also a good time for employers to consider how and whether they will work with third party vendors to meet their ACA information reporting obligations.