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1095 Audit

1095 Audit Services For 2016 Prior Year Reporting Submissions

The IRS have been sending out Letter 226-J for 2015 submissions, mostly based on Recipient Eligibility.  It is now starting to send out 2016 penalty letters.  A strong likelihood exists for the IRS to expand its net to include other reporting irregularities for previous years.

We have put together specific audit services geared to independently and objectively mitigate the IRS ACA penalty risk. Said another way – would you like to obtain assurance your supporting ACA-related data, processes, technology, governance and reporting are working as needed?

[1] Recipient Eligibility Accuracy Re-Calculator

Are you worried about Penalty A (70% offer threshold in 2015 and 95% in 2016/2017)?     Do you have 100% confidence all ACA eligible employees were identified and offered coverage in any given calendar year? Are you worried that you’re lacking sufficient IRS Letter 226J support?

Using our Smart1095 engine, our data-driven audit methodology independently and objectively recalculates recipient eligibility.


  • What You Get

An independent and objective list of eligible recipients for each of the respective Measurement Periods for the respective reporting year(s).

We then compare this list to what you officially reported, and, if interested, we can then help you resolve the individual employee inconsistencies if threshold percentages are not met.


  • What We Need

To proceed we simply need: ACA calendaring (i.e. Measurement Periods), Census data, Benefits data and Hours Worked data.   In the event waiver information is maintained outside of your PR/HR system, we also need a list of recipients that waived coverage.

[2] 2016 Data & Process Review (High-Level Internal Controls Audit)

Would you like high-level assurance about your internal reporting process, as well as if your 1095/1094 platform (vendor, software) produced information sent to the IRS that was structurally accurate?

Using our Smart1095 system, we can painlessly take your submitted data to produce a report that provides top-line data summaries that can uncover systemic data problems.

  • What You Get

We’ll provide an independent and objective set of line 14 Offer of Coverage and line 16 Employee Status Control Counts (by distinct code value) and will compare these expected summary numbers to what was submitted to find any statistically relevant anomalies.


  • What We Need:

To proceed we simply need: Census data and Benefits data as well as some high-level information about the plan, such as the plan’s characteristics (e.g., MV, MEC, Offered to All, Premium), waiting period and benefits termination rules. In the event waiver information is maintained outside of your PR/HR system, we also need a list of recipients that waived coverage.

[3] Proactive 2016/2017 Data Analysis & Data Process Improvements (Detailed Audit)

Get ahead of the IRS. Let us dive into your data, expose potential data problems and help you fix them in advance (and not within your 30 day Letter 226J reply window).

If you already received Letter 226J and/or know your  effort was sub-par, how confident are you that what you submitted is factually correct?

We can perform a full detailed audit tailored to your precise needs.  Using our Smart1095 system, however, will make this process far more economical for you and us!

  • What You Get

An independent and objective assessment and improvement strategy, if needed.   Deliverables include tailored data reports that can be provided to the IRS in the event you receive a Letter 226J, and an in-depth audit report outlining steps you need to take to assure compliant 1094/1095 forms in the future.


  • What We Need

To proceed we need to interview your team, your data, plan design, and submitted IRS reports.

Please Note:   We also can tailor one of our additional audit services to meet your exact needs.   Basically, we need to really understand your data, data source, and a number of other factors before really understanding how best to meet your audit and information discovery needs.


> Employer profile
> Aggregated ALEs
> Plan design
> HR/Benefits data
> Prior Year 1095 output


> Scenarios
> Data load
> Expected results
> Actual results
> Exceptions
> Avoided fines


> Aggregated ALEs
> At-risk employees
> Offer of coverage
> Monthly premium
> Employee status
> Dependents


1095 Audit, a service of ACA Managed Services

795 Franklin Avenue
Franklin Lakes, NJ 07417
855.259.6088 fax

1095 Audit