The IRS released draft forms for the employer ACA reporting requirements late yesterday. I know those of you hoping for another delay of the employer shared responsibility requirements beyond 2015 aren’t happy to see the forms because it makes another delay less of a reality. Now that we have the draft forms, there are two big issues for employers (1) the instructions — hopefully to be released sometime in August — are a critical missing piece of the puzzle, and (2) data tracking needs to begin in January 2015 for reporting in early 2016. The challenge for many is that the data must be aggregated from multiple systems and this creates a huge strain on IT resources that typically have limited short-term capacity.
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