Submitting Prior Year ACA Files

We received a letter from the IRS regarding our 2016 ACA information not being submitted through AIR. What we didn't know in 2016 was we needed to do a Test file (learned this in 2017), so when we loaded our 2016 information it essentially did not go through, when we thought it did. We are not having to submit 2016 data to the IRS through AIR and there is not a lot of information from Infor on how to do this. According to the IRS we need the Manifest to be in formatted to the 2017 schema, and the data has to be in the 2016 schema. If anyone has experienced uploading a prior year successfully please share how you were able to get the information out of Infor and accepted by the IRS.

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Comments

kristen-rotzenberg

We had a similar situation and decided to complete our 2017 reporting first, then submitted for 2016. I was surprised at how smoothly the 2016 reporting went. We initially thought we needed to submit replacement files since we did attempt to submit for 2016 and were rejected as we were not in production. But, we confirmed with the IRS and they told us that we needed to submit original files. My suggestion would be to call the IRS and confirm how you need to submit it. That will determine your Submission Type on BN299. Make sure the Prior Year flag on the Manifest tab is set to 2 (yes). This will generate your forms file with the 2016 format. Other than that, we used the same parameters on BN299 that we did when we originally ran the jobs for the 2016 data. Also, it's always good idea to download the schemas from the IRS website and validate them prior to filing.

Attachment_4321.zip

Legacy Contributor

Thank you! I did call the IRS and they told us we needed to do replacements even though we never made it through. I thought the previous year flag is a 1. We tried submitting the originals we had saved from 2016, but we got an immediate error and then I did the process all over again and still get the same error. Today's call with the IRS did not go so well. We were told to correct the file and re-submit, but there is nothing that tells us what needs to be fixed. We are going to try calling again to see if we get someone new. Thanks for the information!

kristen-rotzenberg

I feel your pain! I spent many, many hours on the phone with the IRS this year. If the submission status shows rejected, you need to submit a replacement file. If the status is Accepted with Errors or Partially Accepted, there will be a txt file you can download with the records that were errors. In that case, you would submit a correction file. This is a bit more complex. In both cases, you need to add the receipt ID from the IRS to the File Name on BN89.1. If there is actual data that you need to correct, that would need to be done but the form is different depending on the type of data and individual (I don't have the KB number but search for How do I prepare my data for ACA Correction processing). Then would have to mark each record that needs to be corrected with a Correction Type C - Correction on BN97.1. On BN299, you would need to complete the Correct/Replace tab as well so that the receipt ID from the original submission is added to your new files. Also, your submission type would change from Original to either Correction/Void or Replacement. Good luck!

Legacy Contributor

So should my 2016 files have a 2 for prior year id or a 1?

Legacy Contributor

We also received a letter from the IRS saying our 1094C page 2 was not complete (for 2015). Isn't that data supposed to be included when you produce the BN299 file for electronic transmission? None of the employee counts came through on the BN299, wondering if a parameter wasn't set correctly or something else was done wrong. Thoughts?

kristen-rotzenberg

As long as you have the counts on BN27.1, I'm not sure why it wouldn't be on the 1094. We were a new Infor customer beginning in October of 2016, so the 2016 reporting year was the first year we used Lawson for ACA reporting. I'm not sure if there was a problem with the program prior to that. Might be worth opening a ticket with Infor, they may be able to tell you.

Legacy Contributor

I've never gotten a very clear picture of all the different forms that need to be completed. Would I run the BN255 and get the counts and then enter this information into the BN27?

Legacy Contributor

Hi Margo,

That's what I did for the 2017 submission. I also entered other missing information using BN27.1

Legacy Contributor

Hi,

I am about to submit my 2016 corrections . I noticed couple error messages when I validate the Manifest.xml file against the 2016 Manifest XML Schema. Has anyone experience this?

Legacy Contributor

When validating the 2016 Manifest.XML file. I received an invalid UniqueTransmissionId element and invalid value for element ChescksumAugmentationNum . Has anyone encounter issues with Manifest.xml validation? Thanks!

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