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Definition – The management of vendor(s) providing any ACA-based service including, but not limited to hours counting to determine eligibility to ACA IRS reporting and filing.

Rationale – Helps mitigate IRS penalty risk stemming from vendors that fail to meet contractual obligations.

1. Timely Data QA – Vendors should review client-provided data implementation and throughout the contract term to ensure client-provided data is credible and usable.

2. Interim Reporting – Employer should review vendor-produced interim output to ensure vendor is progressing towards stated goals.

3. Periodic Status Meetings – Employer should have periodic status meetings to review progress.

4. Part 2 Line 14 Offer of Coverage code SLA – Service level agreements (SLAs) should be baked into contract to ensure vendor is responsible for coding accuracy.

Action Plan

  1. Review contract
  2. Include SLAs in contract
  3. Include milestones in contract
  4. Include customer support provisions in contract
  5. Set meeting calendar

Since we are no longer in a “best efforts” year, employers should embrace best practices or simply accept the dire likelihood of material penalties. In order to mitigate future risks employers should thoroughly review and improve their supporting processes and technologies. Employers have the opportunity to fortify their environments and avoid penalties. As they say, “there’s no time like the present – do it now!”


About The Author: Howard Gerver, of ACA Managed Services, is an authority on 1095 compliance. He and his team of ACA experts are the go-to specialists for companies who wish to avoid trouble with the IRS. They offer a range of ACA services, including ACA audits (also known as 1095 audits)