ACA Reporting Q&A – EINs (ScreenCast 03)

Question: We have a controlled group with lots of employees. Somehow we are able to use the same EIN on paychecks for every employee regardless of which entity employs them. Can I use this single EIN for all of my ACA reporting?

Answer: No. You might be relying on the common pay agent rules or the common paymaster rules  to simplify paychecks and W-2s.  But those rules don’t help you for ACA reporting.  You will still need to use each separate ALE Member’s EIN on the 1094-C filed by that ALE Member and the 1095-Cs issued by that ALE Member.


ScreenCast. Click on the ScreenCast below for a related discussion with Tim Goodman and Bob Seng. The ScreenCast refers to an earlier episode by Bob Seng and Liz Deckman on terminology. You can find that one here. (Liz/Bob on ACA Terms). The 1094/1095-C instructions contain useful definitions. You can find them here.  (IRS)


Bob Seng

With plenty of experience in private practice and as an Assistant General Counsel for Pay & Benefits in a Fortune 50 Company, Bob understands that employee benefits law isn’t for everyone. That’s why he takes pride in listening carefully and responding with clear answers and advice that can be followed by busy clients.

Tim Goodman

Tim Goodman works with employers on medical plans, retirement plans, executive compensation, and a wide range of benefits. Tim works with a broad array of employers, with a special focus on assisting cooperatives, agribusiness companies, hospitals and health care entities, banks and financial institutions, and Alaskan Native Corporations.Employers have Tim provide advice on health care reform (the ACA), wellness plans, and other welfare plan matters (ranging from cafeteria and health FSAs to severance and tuition plans). With respect to health care reform, Tim advises employers on the new fees (from the employer shared responsibility fee to the Cadillac tax), assists them in preparing for reporting on Form 1095-C, and explains the new requirements ranging from notice requirements to plan mandates.Tim recognizes the complex nature of the rules governing retirement plans and works with employers to review operations, address errors, and help employers maintain the tax-qualified status of their plans. Tim advises employers on qualified and nonqualified retirement plans (including defined benefit, 401(k), 403(b), 457(b), and 457(f) plans, and section 409A).

You may also like...