After previously releasing draft versions of the forms in July, the Internal Revenue Service (IRS) released the final versions of the 2016 ACA reporting forms in early October – less than four months out from the first of the two reporting deadlines. Fortunately, the final forms do not differ significantly from the forms used for 2015 reporting. There are, however, some key differences for employers to keep in mind.
As employers begin the final countdown to the 2015 Affordable Care Act (ACA) reporting deadlines, an important consideration to keep in mind is the IRS’s assurance that employers who make a good faith effort to comply with the requirements will not be met with filing penalties this first year. This penalty relief should provide some comfort, but employers may be left wondering exactly what a “good faith effort” entails. Generally, a good faith effort is one made with honest, sincere intention. In the context of ACA reporting, how will an employer be able to demonstrate an honest, sincere intention to comply?