Good morning, everyone, and thank you for joining our webinar today. All summer long, we’ve been doing Back to the Basics series, and this is our final one, avoiding the top five employer mistakes in ACA reporting. My name is Robin Carlini. I’ll be your webinar moderator today, and I’ll be introducing our host in one minute. Just want to go through a little disclaimer. Solirix, we have a lot of ACA knowledge. We’re ACA experts, but you still would have to ask specific questions to your legal counsel. And a little bit of housekeeping. This webinar is being recorded. All registrants will receive the recording tomorrow, and you can type in either the chat function or the Q and A function any questions we will answer throughout and mostly towards the end of the webinar. Also upon exiting, there is a survey. If you don’t mind filling that out, the biggest question is what ACA topics would you like to see in the future? And that helps us guide these webinars. And we’re also asking polls throughout to keep everyone awake. And now I’m introducing Kelly Smith. She’s director of ACA Compliance and Training here at Solaris. You’re all very lucky to have Kelly’s knowledge today. Kelly, can you tell everyone a little bit about yourself? Absolutely. Well, welcome, everybody. As Robin mentioned, I am Kelly Smith, the director of ACA compliance here with Solarix. I have been with Solaris, it’s actually twelve years in October, so it’s been a long time. And I was here at the very beginning when ACA came around and we started handling EC services for clients and building that department out. So I’ve got a lot of experience over the past decade or so in that area. I look forward to walking through the webinar with everyone. And a little bit about Solirix. You can just see our stats on the side. One in four ALEs use Solirix for the ACA reporting in the United States, which we’re very proud of. And you can just see our other statistics, but we do mitigate a lot of penalties. We’ll be going through some penalty risks in this webinar, and we’re very good at mitigating these penalties. Okay, and we’re going to start off with a poll. I’m going to go ahead and get that launched. Hey, what is your current status with ACA reporting? Are you a Solaris customer already? Are you currently evaluating ACA vendors? Are you handling ACA internally? Do you outsource to a third party or anything else? Robin, I’m curious to see how many of our current Slayerus customers might be on the line. Quite a few, looks. Let’s It’s great. But as always, we always welcome those who are with other vendors sharing the knowledge and kind of providing some information on the ACA process and some of the areas that seem to be some pitfalls for folks. So fifty percent are customers, welcome. We’re glad you’re here. Twenty five percent handling ACA internally. So I understand why you need this knowledge. And then if you out source to another third party and other. Thank you for answering that just gives us a little knowing who’s on the line. And we’re going to start off this webinar with a little ACA refresher. Okay, All righty, so positioning ACA. So just kind of going over some of the refresher items. So who has to report? So the mandatory for those who have fifty or more full time or full time equivalent employees. So there’s some formulas you have to do to kind of determine what that count is. You’re certainly going to want to make sure that you’re looking at all of your employees, not just your traditional full time folks. So it’s really important you understand that how that works. Basically, you’re reporting is you’re reporting to the IRS about the company’s coverage and the offer of coverage that it’s extending to those full time employees and making sure that that offer is affordable and meeting the mandate requirements. There are deadlines, obviously, for distributing the ten ninety five C forms that go to those individuals and submitting the electronic filing to the IRS in and of itself. So March is the deadline of the new year for the prior year filing. So compliance should be managed year round. That’s something we’ll talk about as we go through the webinar, kind of being proactive in the ECA process. And then ultimately, what happens if you don’t file if you’re required? Obviously, is some significant potential penalty risks for noncompliance or inaccurate reporting. And again, those are a lot of things that we’ll walk through in the webinar today. So why ACA compliance matters? So as we mentioned that there’s employer responsibilities, again, determining if you’re an applicable large employer and what that status is and making sure you’re filing if you’re required to do so, Offering affordable coverage to those eligible employees, making sure that that offer is meeting that criteria. Tracking your eligibility and offers of coverage, and then completing that annual ACA reporting. So all of those pieces are the employer’s responsibility and making sure you have a good partner that can help. You keep line of sight on all of those areas and making sure you’re meeting all those requirements. The risk of non compliance, as we mentioned, those IRS penalties, they can be steep, nothing worse than getting a penalty letter in the mail. So you want to make sure that you’ve got your eye on the ball there and making sure you’re meeting all of the responsibility filing requirements. For incorrect reporting filings, a lot of those penalties we see as a result of incorrect reporting, data sets, making sure your employees are accurately categorized, things of that nature. So we’ll dive into some of those risks a little bit deeper as we walk through the webinar. So the penalties, what are those penalties and what are they for? So there’s two specific penalties. There’s a penalty A and penalty B. Penalty A is the most expensive penalty oftentimes because it looks at a higher volume, although per year of the dollar value is higher for the B penalty. But the A penalty essentially is indicating that you are, if you fail to offer ninety five percent of your full time or full time equivalent employees coverage, this is where the penalty A could hit in. Penalty B really looks more about the affordability of the offer and making sure that you’re meeting the minimum value criteria and it’s meeting some of the different services that are required within that medical plan offer. So those two penalties can be significant depending on the different areas that hit. You’ll see that the twenty twenty seven reporting year, those penalties are going up for both the A and the B. So as they compound those things, you really need to be mindful of the compliance requirement because those penalties can be significant if they come your way. So the affordability percentage, this is where the part of the mandate where it’s really looking at determining the affordability of the offer of coverage. So one of the mandate requirements is that the offer of coverage has to be affordable within a certain benchmark that the IRS releases every year. So for twenty twenty six, the affordability percentage is nine point nine six percent. So if an employer is using the federal poverty line amount, it’s one hundred twenty nine point eight nine or one hundred thirty two point four seven, depending on if you are a January one benefit plan year or an off cycle medical benefit plan year. And so these are really those figures that you need to keep in mind when you’re looking at the lowest employee only contribution that the employee has to pay for that coverage, because that’s where the calculation of that affordability is looked at. So it’s really important that whatever methodology you’re using, whether you’re managing the ECE process internally or you have a vendor, that you’re really mindful of what that amount is and that that affordability calculation is being done correctly, that you’re meeting that requirement. You’ll note here in twenty twenty seven that they are increasing that percentage. So that will have a direct effect on the dollar value to meet the affordability calculation. So there’ll be some changes into twenty twenty seven for employers to look at as well. So the top five employer mistakes. So this just kind of highlights what those are, and we’re going to kind of go into each one into just a little bit more detail we walk through the webinar. So some of the top five mistakes we really see are incorrect full time employee determination. So identifying who’s a full time employee, missing or incomplete employee data, measurement period administration, measuring the hours of service for employees, also looking at incorrect EINs or company legal names, or if you’re a control group failing to file for one of those entities, reporting errors clerical mistakes. So these are some of the big ones that we see. Okay, and now we have our next poll. Go ahead and get that launched. How confident are you that your current ACA process is protecting you from these common mistakes Kelly just went over? Are you very confident we have a strong process in place? Somewhat confident there are areas we could improve, not very confident we have compliance gaps, or you’re unsure? I would like to think our customers answering very confident, Kelly. Yes, absolutely. Would too. But those on the line, if those who are attending today are in the area of somewhat confident or not very confident, hopefully we can kind of outline and highlight some areas that they really need to focus and offer them some good resource information to help them move forward and feel a little bit more confident in what they’re doing. Absolutely, and no surprises here. Thirty eight percent very confident. Most everyone, fifty nine percent somewhat confident, and six percent not very confident. Okay, all right. So for that six percent, we really hope today’s webinar will kind of give you some insights into a couple of things and kind of help you redirect where you might feel a little unsure about the process. All right, so to kind of dive into those different five areas that we talked about and kind of give you some real world examples, Robin has been on enough webinars with me that I have a tendency to do sort of analogies and give real world Which is wonderful, by the way. That I think is kind of helpful to put things in context, right? So incorrect full time employee determination. So this is an area where using the wrong full time standard. Back in the day, forty hours was seen as your full time hour per week benchmark. Post ACA, that’s really looking at thirty hours per week on average or one hundred and thirty hours per month. So making sure you really have line of sight on who your full time folks are and how that calculation is being done. Misclassification of variable hour employees, again, tracking and monitoring the hours of service becomes really important for those variable hour employees. When they work different hours week to week, these are those folks that you really want to measure during whatever measurement method you’ve chosen to use and making sure that if anybody meets that hours threshold to become ECA eligible, that you are classifying them correctly and those offers of coverage are being extended. So we see a lot of confusion with employers around that process and misapplying that measurement method. So you’ll see that other option there in the slide here, where trying to determine whether they’re using a monthly measurement method or using a look back measurement method, making sure they know which method is going to work best for their organization and applying that methodology correctly and consistently across your designated job classifications. Some other things, failing to aggregate hours, we see that. And then mishandling some new hires, understanding what the requirement there is. But mostly really classifying your employees is really a big issue for those full time folks. Then we’ve got missing or incomplete employee data. So to give a perfect example of this, lots of times what we see in this regard is not really having employees categorized in either the right job class and understanding if you have a specific job classification, the employees in that job class, are they full time or part time? How is that offer being extended? And then making sure that you’re updating your employee data ongoing. Peggy Sue is hired, here’s her new hire date, she becomes eligible. Down the road, she has maybe a life event or a status change, maybe moves from full time to part time or terminates. Making sure that those dates and that those series of events that happen with an employee during the course of a calendar year are updated and captured simply because the code combinations can change and your reporting details could be significantly impacted if you’re missing some of those pieces. And then the measurement period eligibility tracking. I think of all of the different areas that we can touch on today, I think most employers have the most difficult time with the measurement process and really understanding how that works, knowing what their measurement period is. Again, if they’re using a monthly measurement or if you’re using the look back method where you’re looking back either from three to twelve months retrospectively and aggregating the hours for individuals and then measuring those hours to determine if they meet that hour threshold to become full time. And then what happens if Peggy Sue during your twelve month look back, for example, works an average of thirty hours per week or more during that measurement process? What happens next? How do we move her to a job classification that will now extend that medical offer to her? How do we push that offer to her and then allow her to either enroll or waive that coverage and track that as that happens through the course of the year so that we’re indicating that the offer was extended and the code combination and reporting during that period are accurate for that individual. Incorrect EINs and company legal names. So we see this a lot where you’ve got a company that’s a control group perhaps, and they may not necessarily include one of the EINs that should be reported on. So the IRS’s expectation is for each unique EIN to submit an electronic filing. So everybody would file, each of those EINs would file and provide ten ninety five forms for the applicable employees within that company. So lots of times we see one of the entities gets missed, Or in the filing process, many times they may call a particular company or group of locations specific names kitchen, dining room, bathroom, what have you. But the actual company name is ABC Inc. And so lots of times when they’re filing, they’re using their common location names in the filing process instead of the legal company entity name. So those are all pieces of information that are really important to make sure the filing is completed and can be pushed accordingly to the IRS without getting rejected. And then ten ninety four, ten ninety five code mistakes. So as it relates to the ten ninety five C form, I think the code combinations can be a little tricky for folks because some of the codes can have a multi use and then understanding the IRS’s expectation surrounding the different code combinations. So just making sure that you understand what codes are used in what scenario, and you have a partner who can help you navigate, are those codes correct? Should Peggy Sue have a two d for this given month under line sixteen because she’s in her waiting period? Things of that nature, really understanding the story that’s told behind those code combinations to represent what happened with that employee during that reporting year and making sure that you’re not missing forms for folks. Lots of times we will see scenarios where self insured plans are failing to include their retirees or their COBRA individuals who continue coverage under their group plan. So just having an insight into what is required and what information needs to be provided. So a couple of other common ACA mistakes. So some increased risks can be when you’re using a manual process or spreadsheets, so you don’t have a true system of record that can capture information or pulling information from multiple sources and trying to smash the information together. Lots of times we will see when you’re pulling information from three or four different places, and it’s not really living in one bucket, if you will, there could be gaps in maybe life events if somebody changes from full time to part time or vice versa, hours of service maybe not captured the way they should that could yield incorrect measurement results, things like that. Overlooking control groups, which we talked about, making sure all of the unique EINs and entities are included, not monitoring regulatory changes, making sure if you’re a team that is managing this internally, that you have some way of keeping track on any regulatory changes that happen when they change the affordability percentage, perhaps from year to year, making sure you’re capturing those or anything else that might happen there. And then relying on maybe sort of a light solution, one that doesn’t really, that requires you to kind of know more surrounding the code combinations and the IRS rules, expecting you to populate those codes, using a system that will already pre populate code combinations based on the data you provide. So Peggy Sue is hired, and he can recognize the 1H code, and then when the 1H code would change to the offer code, things like that based on the events or activity that’s happened for those particular people versus the group having to try to identify which code should we be using and having to populate that themselves. And then lastly, failing to respond to IRS notices. I think this, as of late, we know that the IRS is now releasing IRS notices for twenty twenty four, potential penalty notices, and they’re looking at the twenty twenty four reporting year. So it’s really important that employers really have a way to manage when mail comes in from the IRS if there’s any kind of notification that it doesn’t land on somebody’s desk and it stays there and nobody gets it open, or it filters around the mail room because nobody knows where to deliver it. That you have a system in place for when it arrives, it gets to someone, they open it, they see what it is, and that it is designated to go to the applicable party that can take action on what next steps might be. That seems like an easy thing, but it gets overlooked, the easiest thing. Yeah, absolutely. So why these mistakes matter. So all the mistakes that we just sort of talked about and some of the key areas and elements and why they matter. I think the biggest one is really the financial risk. The potential penalties can yield up to the millions. And so for organizations, those kinds of penalties can bankrupt or really impact an organization significantly. So you really have to be mindful of making sure you’re maintaining compliance, have systems in place to cross check. And then again, more importantly, should you get a potential penalty notice, which can happen for a variety of different reasons, but you have a method in place to proactively receive those, open those and take action on them so that you can appeal and mitigate that before it gets out of hand where you don’t have any kind of recourse have those penalties waived or mitigated by the IRS. Operationally, mistakes often lead to, again, as we talked about the notices, audits, corrections. So operationally there’s time that’s involved with your team that might have a variety of other projects that they need to get to, but it could take away and divert some of those resources and time because they have to go in and help with audits, corrections, things of that nature. So there’s an operational impact as well. And then obvious compliance confidence, a strong process and systems in place and cross checks and methods to sort of navigate yourself through filing season and not just necessarily at the end of the year into the beginning of the new year when it’s really that time to produce forms and to do the filing. It’s really more of a proactive approach looking at ACA and the compliance piece proactively throughout the calendar year. So you don’t have to look at it every day, all day, but at least having a quarterly cadence where you’re stopping and saying, okay, have we updated all of our new hires? Have all the termination dates been added? Are we sure that we’re tracking and managing any status changes for employees who move from full time to part time? Are we actively monitoring and managing our measurement and tracking of the hours of service and keeping an eye on who might become ACA eligible and making the necessary shifts to those employees so that that offer of coverage is extended. So really being able to feel confident in the process and procedures that you have in place goes a long way to really helping mitigate some of the other factors that we talked about earlier here. So your ACA audit readiness. So what do you need to do to get ready? And we’re going to start this section with a poll. We’ll go ahead and launch it. And thank you everyone for your participation in these polls. If the IRS contacted your organization tomorrow, how prepared would you feel? Very prepared, somewhat prepared, not very prepared, not prepared at all? All answers are understandable. Right, absolutely. It’s a lot to navigate when you get something, if you were to get an IRS notification. Hopefully we hear a lot of very prepared or somewhat prepared, but again, for those of you who might feel unprepared, we’re hopefully we’ll be able to give you some insight in some areas to maybe fine tune some things should that come your way. That’s Kelly’s specialty, mitigating those penalties. It is helping navigate those waters. Yeah. Okay, twenty five percent very prepared, fifty percent somewhat prepared, ten percent not very prepared and fifteen percent not prepared at all. So we hope we can help you. Absolutely. Absolutely. And feeling somewhat prepared, I think is probably a natural response for anybody because no one’s prepared when an IRS notice lands in the office. I don’t think anybody’s really prepared for that altogether. But if you’ve got the right partner and you kind of understand what you need to do, I think it goes a long way in helping ease some of the stress that goes along with getting that type of notice. Absolutely. All right. So ACA audit readiness. So prepare before the IRS comes calling. So again, we talked a little bit about some of the top five mistakes and sort of some of the pitfalls that can happen during the process. But what can you do proactively to prepare should one of those things happen and you get an IRS notice? Or if you haven’t gotten one, just putting things in place. Documentation is the best practice. If you’ve attended any other webinar or been on any other call with me, you hear me say often from the IRS perspective, if you didn’t document it, it did not happen. So you have to make sure that you have some type of documentation and recording process in place. So everything that you’re doing should have an audit trail. So you’re keeping up with your employees, their new hires, their waiting periods, the offers of coverage. If they’re waiving the offer of coverage that it’s either your system of record that is sort of tracking all of those pieces of information, or you’re getting documentation if you’re using a paper version, which I’m hoping that many of you are still are not using necessarily paper and you have more of an electronic methodology. But if you’re still using paper that you’re documenting that and keeping all of those documents, the affordability calculations, really having a firm idea of what your medical plans are, what the lowest employee only cost is, comparing that to the affordability threshold for that reporting year, and that you’re documenting whatever your measurement method is that you’re using and what your business practice is to manage that process. And obviously with the ACA reporting from year to year, always maintaining all of your records, copies of the ten ninety five C forms that were distributed, all of the ten ninety four information, and all of those pieces of information that you need to have in your arsenal should the IRS come calling. That audit trail, again, as we talked about those employee records, it’s when, if the IRS were to come calling and you get a notice, one of the things that they’ll include in one of the most common notices, which is the two twenty six notice, is a list of employees that are in question. And so you need to have the documentation to be able to go back and prove, oh, you know what, these were the codes that were sent. But really what happened with Peggy is she was hired and then she terminated and we didn’t update the termination date. So really, the codes that were sent from October forward were incorrect because we failed to update the termination date. Those types of scenarios. So being able to have those records to be able to prove what has happened and then reply to the IRS in the effort to get any of those penalties mitigated. And then filing and internal reviews. You’re always going to want to make sure from year to year when you’re doing the process, whether you’re doing it internally, you have a partner that’s helping you with that, a system of record that’s managing that, that you’re looking at that information every year. As you do your ten ninety five C forms, spot checking employees, employees that have terminated, maybe one that’s had a life event and moved from full time to part time or vice versa, some new hires and making sure that the codes and the details that are indicated on their ten ninety five represent what actually happened with that employee. So if you just do a small population, a percentage of your population and everything looks fine, you should be good to go. If you’re finding some consistent discrepancies in that population, step back and get back with your team and re review what the information is, again, being proactive before you move forward. And that’s the same for the filing as well, making sure you’re looking at that information, information looks right, addresses, contact information, things of that nature before the filing is submitted to really give yourself a good sense that you’ve touched it, felt it, it looks good, let’s send that in. And then obviously keeping all of your documentation. So documentation, best practices, as we talked about, kind of I just alluded to in the beginning there, your employees’ hire dates, their employment classifications, eligibility terminations, what benefits were offered? Are you measuring these folks? And if you are, what’s the measurement method, their stability period, things like that? Did the employee elect or waive the offer of coverage? So keeping all of those records and all of that information is vital. Your internal ACA audit checklist. So before the reporting season, here are the things that you need to have on your checklist to be able to cross off and feel confident that you’ve got all of these things and have a good understanding of them. So your employee classifications are accurate. So do you have multiple job classes, full time, part time, and seasonal, for example? So are all those individuals in that full time classification full time? Have they all been reasonably expected to work thirty hours per week or more on average? Or did they measure and meet that criteria and are now full time? So just making sure you understand what your classifications are and the employees within those classes and what offers of coverage might be extended based on that classification. Are your measurement periods documented? So whatever measurement method you’re using is that documented so you can be consistent in that. If you’re doing a monthly measurement or if you’re doing a look back method. So if you’re doing a twelve month look back, for example, you have that documented. What is that measurement period? What we find lots of times is if you’ve got a group who is a January one benefit plan year, for example, they may use a measurement period of November first through October thirty first every year to measure everyone so that once they have their findings, anybody who becomes ACA eligible, they can allow them to enroll during that same window where their open enrollment might happen, November, December, so that the offer would be effective January one. That’s just an example of that type of thing. But just making sure you have it documented and you’re clear on what that measurement is when you’re doing it, what your administrative periods are, and then what your stability period would be moving forward for any individuals. Are your offers of coverage tracked? Obviously, you want to have either a system of record that tracks when you extend an offer to an individual. Again, if you’re doing the paper version, making sure you have that documentation and it’s archived somewhere on file. And then can affordability calculations be reproduced? You’re just really going to want to make sure that that affordability calculation and whatever safe harbor affordability method you might be using, you have an understanding of what that is. If you’re using the federal poverty line, if you’re using rate of pay based on annual salary or hourly wage, how that calculation is being done and can it be reproduced should you need to do so if you get a penalty notice to prove that the offer of coverage was affordable. Can you explain every line fourteen and sixteen code? I don’t know that every employer will be able to explain those codes as well as someone like myself or someone who has that, who does this every day, all day. But just making sure you have a general idea of when Peggy Sue was hired, the months in which before she became an employee, you should always see a one H 2A for any month in which somebody prior to their date of hire, because they weren’t an employee. So kind of having a general concept of what some of those codes mean. But I would definitely strongly say whether you’re doing it internally, you have a third party that’s doing it, or you’re using, some other vendor to help you with it. If you’re looking at the codes and you don’t understand what they mean, you need to ask someone, okay, I’m looking at Bob and I know Bob was hired in January, but these other codes in the front kind of look funny or the codes at the back look odd because I know he terminated in October. That’s where you would need to ask and be proactive for them to explain the code that I see here for Bob, are they really telling the story of he was hired in January and then he terminated in October? So being able to have access to those experts who can help you clarify if there are some questions about specific employees or the codes that are represented in and of themselves. And then do you know when and how you’d respond to the IRS notice? I think most employers are just like, what? But after that, the first thing you need to do, and it seems so simple and it seems like a silly thing to actually have to say out loud, aside from having a designated place for it to go and for someone to receive it, the next thing to do is to open it. You would be surprised at how many folks get it and be like, I’ll look at it later and sit it off to the side. There are very specific timelines required by the IRS to respond to those. So what you need to do is actually open the document, open the letter, see what it says, and then reach out to your provider, if you have one, to a compliance support expert or whatever resource you have to try to get an understanding of what type of notice do I have? What is my timeline? And what do I need to do to be able to respond to the IRS timely and to resolve the issue and try to have the penalties mitigated if I can, depending on the situation. So as we always say, don’t wait until the IRS calls. You want to make sure that you have a good compliance strategy in place and kind of a contingency plan, if you will. It’s sort of like, again, I love a good analogy. It’s sort of like when you live in an area that has hurricanes or things like that, you have to have a hurricane preparedness package put together. You have all your batteries, your flashlight, all of the things that you need to be prepared should it happen. The same is true here when it comes to IRS penalty notices. You need to have your compliance strategy in place and all of the things that you need should you get a notice. Okay, I know where to go. All of our archived historical filings are here. Here’s all of the employee information that we need for that reporting year here. And you can easily access that. And then you have a trusted advisor or partner in the ECA process that you can reach out to that you say, we got the letter yesterday. We opened it today. Here it is. Help us guide us through the next steps. We have pulled together all of our information. How do we take it from here? As someone who lives in New Orleans, Kelly, I appreciate the hurricane analogy. Right. So it’s kind of the same. It’s that whole failure to plan is a plan to fail. So you really want to make sure you’re just prepared. Want it and never want to use it, but heaven forbid you need it and you don’t have it. So preparing now always helps. Reduce the reporting errors by being proactive, being engaged with your vendor, or if you’re doing it internally, trying to find some resources and access to information to help you better understand how to do the process, any changes in the IRS regulations, any of the code combinations that are unclear and how those should be used. Strengthen your compliance process, really have a process in place on how it works from start to finish. Respond more confidently to any IRS inquiries. Again, feeling confident should you get a notice, you have all of the things that you need in place. Now let’s put our contingency plan into action so that we can respond to the IRS, which helps minimize disruption in the organization altogether, because it can be a little topsy-turvy feeling when you get a notice in the mail and you’re like, okay, well, do we do? If you have a plan in place, there’s a path forward into what you need to do and it makes it a little less stressful. Given the IRS notices are always stressful, but it kind of helps bring it down just slightly if you have a plan and you have a partner in the process to help you navigate and execute those plans to the end. So anyone on the line here today at the webinar who has received one of those Robin called IRS love letters, what should you do next? So as we talked about, and again, we continue to reiterate, have a plan already in place for if any type of IRS correspondence comes in, who gets it and it gets opened. So again, opening the notice. Obviously you want to address the IRS notice as soon as possible. Again, getting with your partner that helps you navigate that process, reach out to a provider that can offer compliance and IRS notice support if necessary to get some help on that. And making sure you’re understanding what the deadline is for response because it’s very clear on the notices what the response is. Avoid preparing the response yourself as the employer. I think a good rule of thumb that I would say is if you’re going to prepare yourself to at least have had an opportunity to connect with, an ACA expert or someone who has, extensive expertise in responding to IRS notices. Because I will tell you that the IRS, the IRS is real funny about, how you respond, what you respond, and the manner in which you respond. So there’s sort of a framework for what you need to provide them, sort of the language that you use within your letter that seems to yield more success than other versions. So you can prepare it yourself. But again, I would really strongly recommend you find a partner that can help make sure what you’ve prepared is in line with what the IRS will accept to try to get the best outcome. Obviously, we would recommend you reaching out to our Compliance Connect team to help if you have any of that because that’s what we do every day. But again, some employers want to do it that way. But I certainly would recommend you reaching out to someone to get some guidance there. Obviously recommend an immediate extension. You always ask. Sometimes they’ll say yes. Sometimes they’ll say no. Most of the times they say yes, but you always ask for that. It’s better to have more time to pull together all the information you need and to put the response together, maybe to reach out to an ACA expert to help with any of that. It’s better to have more time and then be able to reply and respond sooner than feeling like you’re up against the wall and feeling like you rushed to get the response in. Always reconcile your IRS data and your records. Again, being able to have that system or method in place for here’s where we archive all of our data. Here’s where we’re going to get all of our employee records. Having a plan in place for if you need this information easily accessible and knowing where to go to get it so you’re not trying to run around and eat up valuable time trying to figure out, well, where is this data? How do I find this? How do I get the information? So you want to make sure you have that. Gathering the documentation, obviously, as I mentioned, the IRS says if it’s not documented, it did not happen. So being able to have the documentation you need to defend the notice and to try to get any of the potential penalties mitigated based on the documentation or the circumstances that have happened. When you’re submitting the response, again, if any of you have seen any of the IRS notices, some of the most common ones are the two twenty six notice. And that would allow you to either agree or disagree with the potential penalty. Most employers will disagree because usually in more instances than not in my experience, it is really one of the five pitfalls that we kind of talked about earlier. It’s really that termination dates weren’t updated or code combinations were used and didn’t understand what code should be used. So usually it’s data discrepancies or administrative issues. It’s not really that you failed to do what you were required to do. It was not understanding what code should be used or the data wasn’t updated the way you thought it was, things like that. And those are the types of responses you can give to the IRS to say, actually what happened, this is really what we did. We just didn’t understand the code combinations that should be used or our termination dates didn’t get updated in a timely manner as we expected. So really, these employees you identify really were terminated, that type of thing. So being able to really understand what notice you’re getting, what the IRS is saying is the issue, and getting to the root cause of it, and then being able to provide the data, the backup, and the response to be able to help mitigate those. Okay, and our very last poll question as we wrap up. What’s your next step after today’s session? Are you going to review your ACA processes internally, look into tools and solutions to improve accuracy, discuss internally with your team, know immediate next steps, or you’re interested in more information about Solirix. I’m hoping we see a lot of review our ACA process internally, just in general, even if they’re using another vendor or even using ours, just making sure that they have, again, putting that contingency plan in place and what their compliance strategy is, having all that and making sure that they’re looking at that. So we’ll see what the poll says. You are correct. Fifty percent did say review ACA processes internally. So we’re glad we have that going with you all. And the other ones I will follow-up with you after the webinar based on your answers. Excellent. Excellent. Very good. So virtual high five to all of those who are reviewing their internal. Very good. So some key takeaways. We’ve talked about a lot of things during the webinar today, and there could be some things that are more specific to what you’re looking for. You can certainly reach out to us afterwards and we can certainly assist with anything or answer any questions that you have or whatnot. But I think some of the big things is really, again, ACA compliance really is a year round responsibility. I’m not saying that every day, all day, every month you have to be looking at something, but there are certain, there’s really a certain cadence or rhythm to it that we find to be best and the most successful. A lot of the clients that we work with, we find that are the most successful in the process. They don’t have as much stress or anxiety about the process and their year end filing season goes a lot smoother. Again, quarterly basis is a great way to do that. But there are some monthly cadences as well. If you’re measuring folks, monitoring your employees, just a soft touch point to make sure that those key areas that are so important, you all have line of sight on those because it allows you to, if you see something sort of going a little bit off the rails, it gives you the opportunity to do that earlier in the year instead of bumping up to November right before Thanksgiving, you realize that some major something or other has happened and now all troops have to get on board to try to figure out what’s happening. If you’re doing it a little bit during the course of the calendar year, should something go a slip, you have an opportunity to get that done during the year and get everything back on track. Again, determining your eligibility accurately, making sure whatever your waiting period rules are, that your offer of coverage is meeting the affordability criteria. You’re looking at those folks that you might be measuring, determining who might become ACA eligible, that the appropriate steps and actions are being taken to make sure that the offer of coverage is extended and things of that nature. Maintain clean and complete data. You’ll hear anybody in the ACA world say data is king. So the data drives everything. Your employee data, the medical plan offers, rates, all of those pieces of information are what drives how the ACA reporting yields all of its information as far as the codes and the filing. All of those things are all driven on those different data sets. So you’re going to want to make sure you’re constantly keeping up with your employees, making sure terminations are updated when employees move from one job classification to another, that the dates that are used there are correct. The measurement method and measurement process is nice and tight when you have folks who are being measured and might move from ACA ineligible to eligible, things like that. Then prepare before the IRS comes calling. The hope is that they never come knocking. That’s my greatest wish and hope for all employers who have to manage this process. They never come knocking on your door. But unfortunately, do. And when they do, as I mentioned many times, it’s as a result of a variety of different pieces of information that just was not relayed properly because either the data wasn’t clean or the data wasn’t updated or understanding of the code combinations weren’t in line with what was expected. And so it was more of an administrative issue or data issue that can be easily resolved if you open your IRS notice immediately and you immediately take action on it. So just being prepared and having all of those things that we talked about earlier in place and having that contingency plan and all of the preparedness items ready should they come and call in. Okay, and as we wrap up, please submit your questions. We will answer questions. We have ten minutes left. And just a little bit about Solirix that you can see here. And also, a lot of people might not know, we also have admin systems. That’s the Solirix. They have been admins and Cobra and just about everything you can imagine. So, we’re just not all ACA, but we are ACA experts. And now we’ll take your questions. Next month, we’re going to do Beyond the Basics, Evaluating Your ACA Compliance Strategy. So, there’s the QR code there. And I just dropped in a year round checklist blog, and our resource link is here. And we have a lot of resources. So if you’re looking for something specific, just reach out to me and I’ll send you what you’re looking for. Absolutely. Absolutely. And I hope those of you on the line have the opportunity to join our Beyond the Basics Evaluating Your ACA Compliance Strategy next month. I think that’s going be a great session. And again, trying to help you build that ACA Compliance Strategy and be prepared ahead of time. It helps, especially in September, because if you haven’t thought about ACA before September, now’s the time. Absolutely, as you start to roll into the end of that third quarter and start to hit into rolling into the end of the year, that’s really crunch time and you still have a little bit of time to get things evaluated and on track. So you certainly don’t want to wait any later than that to be able to kind of take a look at what you’ve got going. I have any questions. I’m surprisingly, no, I think you were extremely efficient. Well, thank you very much. Thank you. Hopefully everybody found it informative. I highlighted a couple of things. I know we sort of reiterated a lot about being prepared and sort of having a strategy and especially when you’re talking about IRS notices, again, reiterating having a plan in place for if that notice comes into the mail room, where does that go? Who immediately opens it and what your next step is? Because you’d be surprised at how much more complicated it becomes simply because that piece, there was no plan for that. And you get far down the line and it’s much harder to navigate through having any of the penalties mitigated once it gets really far down the line. So that’s a really important piece, as simple as it sounds to have in place. Absolutely. And thank you everyone for joining today. Spending an hour on ACA in August, you all get an A plus. That’s right, A plus. Gold stars for everyone. Yes. And we look forward to seeing you next month. Thank you, everyone. Thank you, everyone. Thank you, Kelly. Thank you, Oh, you’re welcome, Robin. Thanks, everyone.
