MSP Affordable Care Act (ACA) - IRS Progress in Implementing Individual and Employer Provisions of the ACA - Volume 1

Sep 15, 2026

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MSP Affordable Care Act (ACA) analysis focuses on IRS implementation progress for individual and employer ACA provisions, while identifying persistent operational and compliance challenges. The document outlines taxpayer rights potentially affected, summarizes problem definition and TAS involvement, and reviews issue categories such as shared responsibility payment handling, premium tax credit case trends, and processing delays tied to Form 1040-EZ errors. It includes background from the 2016 filing season and preliminary reporting data on premium tax credits and individual shared responsibility payments.

LanguageEnglish

CategoryPresentations

FormatPDF

Pages11

Reading Time4 min

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Most Serious Problems

Legislative Recommendations

Most Litigated Issues

Case Advocacy Appendices

Analysis of Problem

Background: Filing Season (FS) 2016 Overall Results

Most Serious Problems Legislative Recommendations Most Litigated Issues Case Advocacy Appendices MSP AFFORDABLE CARE ACT (ACA): The IRS Has Made Progress in \#20 Implementing the Individual and Employer Provisions of the ACA But Challenges Remain RESPONSIBLE OFFICIALS Carolyn A. Tavenner, Director, Affordable Care Act Office Mary Beth Murphy, Commissioner, Small Business/Self-Employed Division Debra Holland, Commissioner, Wage and Investment Division TAXPAYER RIGHTS IMPACTED1 ■ The Right to Be Informed ■ The Right to Quality Service ■ The Right to Pay No More Than the Correct Amount of Tax ■ The Right to Appeal an IRS Decision in an Independent Forum ■ The Right to Finality DEFINITION OF PROBLEM The IRS is charged with implementing certain provisions of the Patient Protection and Affordable Care Act of 2009 (ACA) .2 In addition to the existing provisions impacting individuals, some provisions of the ACA impacting employers became effective in tax year (TY) 2015. In order to ensure that taxpayer rights are protected, TAS has been actively involved with the implementation of the ACA provisions. Some of the issues we reviewed include: ■ In 2016, the IRS performed a systemic Individual Shared Responsibility Payment (ISRP)“recovery” to abate certain clearly identifiable ISRP overpayments; ■ Premium Tax Credit (PTC) cases rose to become the fourth highest category of TAS case receipts during fiscal year (FY) 2016;3 ■ Advance Premium Tax Credit (APTC) recipients who incorrectly filed Form 1040-EZ, Income Tax Return for Single and Joint Filers With No Dependent, experienced delays in processing their returns; ■ The IRS has developed procedures to address “silent returns”(i.e., returns that do not have the minimum essential coverage (MEC) checkbox marked; Form 8965, Health Coverage Exemptions ; or an amount for the ISRP); 1 See Taxpayer Bill of Rights (TBOR), [www.TaxpayerAdvocate.irs.gov/taxpayer-rights. The](www.TaxpayerAdvocate.irs.gov/taxpayer-rights. The) rights contained in the TBOR are now listed in the Internal Revenue Code (IRC) . See Consolidated Appropriations Act, 2016, Pub. L. No. 114-113, Division Q, Title IV, § 401(a) (2015) (codified at IRC § 7803(a)(3)) . 2 Patient Protection and Affordable Care Act of 2009 (ACA), Pub. L. No. 111-148, 124 Stat. 119 (2010), as amended by the Health Care and Education Reconciliation Act (HCERA) of 2010, Pub. L. No. 111-152, 124 Stat. 1029 (2010) . 3 TAS Case Advocacy, Figure 4.1.4, Top 10 Issues for Cases Received in TAS, FYs 2015-2016 , infra. 266 Most Serious Problems — Affordable Care Act Appendices Case Advocacy Most Litigated Issues Legislative Recommendations Most Serious Problems ■ Current ISRP exemption procedures impose an unnecessary burden on taxpayers requesting religious exemptions; ■ APTC recipients who receive large lump sum payments of Social Security Disability Insurance (SSDI) may be caught off guard by having to repay APTC amounts, as well as penalties and interest; ■ Whether employees in the newly-established ACA Business Exam unit would receive specialized training on the parts ofACA implementation that impact businesses, including training on concepts such as applicable large employer (ALE), MEC, and employer shared responsibility payment (ESRP); and ■ Whether the IRS would be prepared to handle the additional volume of information-reporting data expected as a result of the ACA provisions impacting businesses becoming effective for the 2017 filing season. ANALYSIS OF PROBLEM Background: Filing Season (FS) 2016 Overall Results The ACA was enacted by Congress in 2010 to provide affordable health care coverage for all Americans. To accomplish this goal, the ACA provides targeted tax credits for low income individuals and for small businesses, while imposing a personal responsibility on individuals to have health coverage.4 During the 2016 filing season, eligible individual taxpayers claimed the P

FAQs

What taxpayer rights are impacted by the IRS implementing ACA provisions?

The document lists the right to be informed, right to quality service, correct tax amount, appeal in an independent forum, and right to finality.

What issues did TAS review during ACA implementation?

TAS reviewed systemic ISRP recovery actions, rising Premium Tax Credit case receipts, processing delays for certain APTC recipients who filed Form 1040-EZ incorrectly, and IRS procedures for “silent returns.”

What preliminary data is provided for the 2016 filing season?

The document provides preliminary reporting data through August 25, 2016 on premium tax credit claims on Forms 8962 and on reporting of individual shared responsibility payments on TY 2015 returns.

Sep 15, 2026

Uploaded by Ivy