Client Questionairre

[Terry D EA]

I know there is not specific guidance with due diligence regarding the ACA. I am a little anal with wanting to protect myself and have decided to create a questionairre that my client's can answer without going into detail. I don't have a jurat statement included yet but think it necessary to add one. I have attached it here for others to look at, use it. delete it or help improve it. This is an macro enable spreadsheet that I plan on just printing. Any and all feedback is welcome.

 

Well never mind apparently a macro enable file is not permitted. I'll try to remove the macros and post again.

Edited January 17, 2015 by Terry D

[easytax]

No direct guidance BUT a "best practices" reference from the IRS is here:  Shared Responsibility: http://www.irs.gov/p...tices 5000A.pdf  This was in one of the "pinned" ACA posts along with some other mentioned "best practices".

[Lion EA]

And, if you're an NATP member, their January magazine had 1 1/2 pages of questions to ask and questions not to ask.

[Lion EA]

Also, I'm using the Engagement Letter from The Tax Book and saw their Health Care Reform Overview that I will go over and have signed for any client who lacked MEC during 2014.  Almost all of mine are covered by employers, so I don't expect much to do for ACA.  For anyone who doesn't qualify to Check the Box, I'll probably follow the NATP questions to hopefully get all the details I need.  I have a couple who began 1 January 2015 with Marketplace policies.

[Terry D EA]

I did look at all of the pinned items but still want something that I can put in the client's file with their signature that they have the MEC. I know there is no specific guidance yet but I bet it is coming down the pipe. Also, and maybe I am a little paranoid, but if I get a compliance audit I want to be sure I am covered. Here is the file in a pdf so I welcom any comments. I will include a jurat statement with signature as well as clean it up and make it look more professional.

ACA Questionairre.pdf

[BulldogTom]

Hey Terry,

 

I appreciate where you are coming from.  I am taking a different tactic in my practice (that some may call reckless - and that is OK).

 

I am not going to grill every one of my clients this year.  There will be a couple of simple questions.

 

1.  Did you have health insurance all year?

 

If Yes:

Did you get that health insurance on the exchange?

 

If no:

Why not?

 

And then I am going to take it from there.  I don't see any reason to subject all of my clients to the questions that may not apply to them.  If they say they had health insurance all year and it did not come from the exchange, I am checking the box and moving on.

 

If they did not have insurance, then I am going to see if there is an exception.  If not, they pay up.

 

If they got their coverage on the exchange, I am going to calculate the credit and include either the additional credit or the clawback on the return.

 

I know I am making this out to be a little simplified, but I just can't go through the brain damage of trying to figure out every possible scenario that might be presented in my office this year.  I am going to take it one client at a time and do the best I can for them.  I will learn things as I go, and hopefully I will recognize when I don't know one of the nuances of the law.

 

Not changing my engagement letter for this.  Just treating it like any other provision of the tax code.

 

Tom

Newark, CA

Edited January 17, 2015 by BulldogTom

[Terry D EA]

Hey Tom, I want to keep it simple as well and have tried to get this think narrowed down so as not to bore too much. I just feel I need something to cover my tail in the event I get asked which probably won't happen. But... being proactive thats all. I did this years ago, int the middle 90's I think, when due diligence first came about for EIC. Folks I worked for at the time said not to worry but look at where we are now with it. Each one of us will probably handle this differently.