Reporting and Notices Services
ACA employer reporting, Medicare Part D notices and PCORI compliance run on fixed dates. A missed date is a common provider error, which is why these services matter for hold-harmless protection.
What to know.
ACA reporting involves Forms 1094-C and 1095-C and deadlines to furnish forms and file them. Part D notices tell people eligible for Medicare whether drug coverage is creditable. The PCORI fee is reported once a year on Form 720.
Whether the protection reaches these depends on the service agreement. Confirm each is named, and keep your own calendar for the dates.
Where to look next.
ACA Employer Reporting
Forms, due dates and penalties.
PCORI Fee Reporting
The annual fee and when it is due.
Creditable Coverage Notices
Medicare Part D notices for employers.
Why fixed dates make for clean evidence.
ACA reporting, Part D notices and the PCORI fee share one feature: each has a date set by rule, so there is rarely any dispute about when the task was due. That makes a miss easy to identify and, if the provider was responsible, relatively easy to document.
It also makes a second calendar worthwhile. Whether your provider handles these or you do, a shared list of dates with a named owner for each makes missed dates visible before they matter. Review the list each quarter and confirm that every date has a service, a person and a confirmation of completion.
Common questions on this topic.
Four questions to settle before you rely on it.
Does the protection cover ACA penalties?
It can if ACA reporting is a covered service and the penalty resulted from the provider’s error. Check the written terms.
Does it cover a missed PCORI filing?
Only where PCORI compliance is a covered service and the miss was the provider’s.
What about Part D notices?
Ask whether the notices are in scope and who sends them.
Should we keep our own calendar?
Yes. A second set of eyes on fixed dates is inexpensive protection.
Which dates should be on our own calendar?
Furnishing and filing dates for Forms 1095-C and 1094-C, Part D notice and CMS disclosure dates, and the annual PCORI filing on Form 720. Add the dates of any notice services you buy.
How do we confirm a task was completed?
Ask for a confirmation each time: a filing receipt, a copy of the notice sent, or a log entry. Keep it with your compliance records.
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General information about compliance service protections, not legal or tax advice. Plan-specific questions belong with your counsel, and we will bring them in.
Related guides.
What Hold-Harmless Protection Covers
The overview this page belongs to.
Compliance Services With Hold-Harmless Protection
What the protection is, what it covers and what to ask.
Plan Compliance Services
The next question on the same topic.
Retiree Drug Subsidy Tax Treatment (Section 139A)
How the retiree drug subsidy is taxed under section 139A.
Where the Rules Come From.
The laws and rules named on this page link to the statute or regulation they come from. This is general information, not legal or tax advice, and rules change, so check the current text.
COBRA Excise Tax (26 U.S.C. 4980B)
The tax on failures to meet COBRA continuation coverage requirements.
ERISA Civil Enforcement (29 U.S.C. 1132)
Includes the daily amounts a court may assess for failing to provide required notices.
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