Benefits Administration Letter

Number: 15- 202 Date: May 1, 2015

United States

Office of 

Personnel Management 

 

The Federal Government’s Human Resources Agency

 

 

Subject: Employer Shared Reporting Responsibilities under Internal Revenue Code 

Sections 6056 and 4980H 

 

Beginning in 2015, applicable large employers (ALEs) are subject to the Employer Shared 

Responsibility (ESR) provisions under sections 6056 and 4980H of the Internal Revenue Code 

(IRC). ALEs are required to file information to the Internal Revenue Service (IRS) about the 

health insurance offered to eligible full-time employees and must also provide information to 

their full-time employees about their health insurance offer and coverage. To assist agencies in 

their administration of these provisions, OPM has provided guidance on its website at: 

http://www.opm.gov/ESR. 

ALEs are required to report health insurance information for calendar year 2015 to the IRS by no 

later than February 29, 2016, or March 31, 2016, if filed electronically. Employers are required 

to furnish employee statements electronically by February 1, 2016. To assist agencies and their 

payroll providers, this BAL includes links to applicable IRS guidance and technical requirements 

for reporting, including the new AIR system and the IRS schema for Information Returns. We 

strongly encourage agencies and their Shared Service Centers (SSCs) to review the information 

available at the IRS website and to take action to become informed and, as appropriate, to 

register for the Affordable Care Act Information Returns (AIR) system at your earliest 

opportunity. Agencies should be aware that the AIR system is the only mechanism for filing 

information returns electronically to the IRS. For agencies that have designated a SSC to report 

on their behalf, they should maintain regular communication with their SSC regarding the IRC 

reporting requirement.

Affordable Care Act Information Returns (AIR) System

The AIR system is administered by IRS and allows for information returns and transmittals to be 

filed electronically. Registration is required to access this system. Software Developers,

Transmitters and Issuer/Payers (Submitters) must complete the ACA Information Return 

Transmitter Control Code (TCC) Application and receive a TCC in the mail prior to 

electronically filing Information Return (AIR) Forms 1094-B, 1094-C, 1095-B and 1095-C. 

Information about registering for the AIR system:

http://www.irs.gov/for-Tax-Pros/Software-Developers/Information-Returns/AffordableCare-Act-Information-Returns-AIR-Program-Did-You-Know%3F 
AIR Program Overview and Dates for AIR Working Group Meetings: 

http://www.irs.gov/for-Tax-Pros/Software-Developers/Information-Returns/AffordableCare-Act-Information-Returns-AIR-Program-Overview

Questions and Answers on Reporting of Offers of Health Insurance Coverage by Employers 

(Section 6056) 

http://www.irs.gov/Affordable-Care-Act/Employers/Questions-and-Answers-onReporting-of-Offers-of-Health-Insurance-Coverage-by-Employers-Section-6056

Tax Year 2014 Schemas for Affordable Care Act Information Returns (AIR) 

http://www.irs.gov/for-Tax-Pros/Software-Developers/Information-Returns/Tax-Year2014-Schemas-for-Affordable-Care-Act-Information-Returns-(AIR)

Affordable Care Act Assurance Testing System (AATS) Information 

The ACA AATS is the IRS’s testing system for information returns and will open for testing July 

2015 for Information Returns that will be processed in 2015. 

http://www.irs.gov/for-Tax-Pros/Software-Developers/Information-Returns/AffordableCare-Act-Assurance-Testing-System-Information

If you have any questions regarding this Benefits Administration Letter please contact Julia Elam 

at 202.606.1560 or email ESR@opm.gov. 

 

 

Sincerely,

John O’Brien 

Director

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