Forms 1094-C, 1095-C

[chuTzPA]

So...who do you think will be taking on the task of filing these forms? I'm playing with the idea and pondering fees.

[Flyboyjohn]

It certainly should be the payroll and payroll software companies and I believe they're all furiously working on software enhancements to accomodate the hours tracking methodology adopted by the Applicable Large Employer.

Developing a compliance system outside of the payroll system would be a monumental task and I've only come across one vendor so far who's tackled it, interested to know of any others since I'm of the belief all large employers are going to need it (preferably by 1/1/2015 but most likely backfilled a year or more from now when they wake up to the need.)

Fees? Aim high!

[chuTzPA]

So do you think the payroll companies will be providing reports to have the forms completed by other consultants, or be completing the forms themselves?

[Flyboyjohn]

I think the new Form 1095-C goes hand in hand with the W-2 (in fact the IRS seriously considered adding the new reporting to the W-2) so my opinion is that whoever prepares, distributes and files the W-2s will "naturally" be doing the same for the 1095-C.

If any payroll or payroll software companies don't add 1095-C services they're likely to be out of business in short order.

Where there will be a need for a third party 1095-C service provider will be:

1. Where the payroll company wants to charge an outrageous amount

2. Where the payroll company (Paychex) won't provide ACA compliance services unless they take over the broker/commissions on the health insurance

3. Where the employer has multiple payrolls on different systems

4. Where the employer changes payroll vendor mid-year

I've only found one company so far that is offering a third party service but I'm sure more will be springing up.

[chuTzPA]

ok that makes sense. perhaps then companies who do payroll internally may look for assistance, but then, if they do payroll internally they may not wanna add costs...

[Silver70]

I was at an APA seminar yesterday, and they said most organizations are making this an HR function.

[coleboy]

Can you tell me who that company is that will be providing 3rd party services? I work for a growing payroll company and am researching what companies are out there providing these services.

[fluffy2]

Has the IRS finalize forms 1094-C and 1095-C?

[ERISAwookie]

The final forms and instructions are finalized. The forms themselves do not appear to have changed at all, but the instructions provide (some) clarifications.

http://www.irs.gov/pub/irs-pdf/i109495c.pdf

[chuTzPA]

any updated thoughts on trends, if any, for those smaller companies that may not have a payroll provider, don't want one, but could use assistance with these forms?

[ERISAwookie]

How many employees does the employer have? If its not an applicable large employer, no need to report.

There are plenty of products and services out there being marketed for the reporting requirements, but who knows whether they will work effectively. Keep in mind that these forms will be submitted for the first time in 2016, so any product or sevice is probably going to have kinks.

If the employer uses payroll software, I have seen some software vendors offering add-ons that are supposed to help with the 6055/6056 reporting. If I remember correctly, Microsoft has an add-on for one of its payroll products.

Depending where you are, you might find some law firms offering "benefits consulting" services to handle the reporting requirements. I only know of one regional mid-size firm in my area that is doing this, but I heard the service comes as a package with other ACA compliance services and has a pretty hefty pricetag. Not too surprising, because the reporting and all the junk that comes with it is a major pain. So I don't know if you would find any law firms willing to actually do the reporting for a smaller fee. The employer can also think about engaging a benefits consulting service or benefits administrator to do the reporting but not sure that would be cost-effective either.

If the employer is really that small the best bet is probably to do the reporting itself (after consulting with benefits counsel, of course).

I'd be interested to see if anyone else knows of smaller employers who are outsourcing the reporting, and if so who is doing it for them.