Picture this: a taxpayer comes to your site, and halfway through the interview, you find out they had (or think they had) Marketplace coverage, but they don't have a Form 1095-A. And if they do have Marketplace coverage, you need that form to complete the return.

Previously, you might not have known there was a Marketplace problem until weeks later, when the client returned with a paper Form 8962 asking you to complete it. Today, if the taxpayer needs to complete an 8962, the return will reject with code F8962-070. "The e-File database indicates that Form 8962 or a binary attachment with description containing 'ACA Explanation' must be present in the return."

Sometimes the most efficient thing you can do is to coordinate a call with the taxpayer and the Marketplace or your state exchange. Facilitating such calls can be the fastest way to help taxpayers resolve the issue without leaving them to fend for themselves in a language of acronyms and terminology they don't understand.

My experiences have been with the federally facilitated Marketplace at Healthcare.gov. You may live and/or work in a state that has set up its own exchange, so there may be some variation in the experience you have calling that state exchange. But the same general principles should apply because when all is said and done, you need that 1095-A information, no matter the source.

Assessing Your Options

There are three paths you can take when there is an issue concerning the availability of a 1095-A. Send the taxpayer online, send the taxpayer home with instructions, or call the Marketplace with the taxpayer.

Sending the taxpayer online is a good option for those who know how to access their exchange accounts. They should be able to log in and find their tax information in either a message or in a menu on the website. But not everyone has that access, and we're about eliminating barriers, not erecting them.

Sending the taxpayer home is an option, particularly if they received Form 1095-A but left it there. They could also go home to call the Marketplace to request another form or to request the numbers by phone. But sending them home means rescheduling their appointment, in many cases, with all the logistical barriers that might present. Asking them to call and get a new form means delaying their appointment by at least a week, and asking them to request the information over the phone may mean they miss some important figures you need. They don't know what you need, and they don't know what they don't know.

Calling the Marketplace with the taxpayer allows you to complete the return in one session. It involves the taxpayer in the return, which opens a conversation about this portion of the return. But if you are going to call the Marketplace, which does take a few minutes of your time that could be spent preparing returns, you need the fastest path to success:

1. Save the numbers of any exchanges or the Marketplace to your phone. The Healthcare.gov Marketplace phone number is 1-800-318-2596. It can also be found at Healthcare.gov.
2. You need to speak to a representative. In the case of Healthcare.gov, that means identifying the language you want to use (English or Spanish), and then saying, "Tax Questions."
3. You'll be placed on hold, but my experience is that the average hold time is about five minutes. Start entering the rest of the return while you wait.
4. When the representative answers, be clear about your role and what you need:
   • "Hello, my name is Brad Martin. I'm a volunteer with the IRS Volunteer Income Tax Assistance Program. I'm working with a tax client who doesn't have Form 1095-A that we need to complete the tax return. If the client grants authorization, would you be able to help me with the information from the form?"
   • I've had almost universally positive experiences with this. The representative will speak with the taxpayer to validate the taxpayer's identity and then ask if it's ok to discuss the information with you. Sometimes the representative will ask how long this authorization should be valid, and "just today" or "just for this call" is fine. You don't need access to their Marketplace application for an entire year.
5. You can now be a part of the conversation between the Marketplace and your client. The representative will tell you that what they're about to share is for informational purposes only, and they are not responsible for any tax errors. Be clear about what you need and the format in which you need it. There are a number of ways this can go. We'll discuss some scenarios and how to proceed in each case.

Scenario 1: Ana Alverez is single with no dependents.

If the Marketplace or the appropriate state exchange has no record of Ana, it may be that she has coverage through Medicaid or some other source, and thus there is no Marketplace application for her. Or there might be an application on file, but they may show that she never had coverage through the exchange. In this situation, you probably don't need to do anything to finish the return. If you receive a reject with code F8962-070, then you might need to attach an explanation to the return indicating that the exchange does not have any record of her having coverage.

Scenario 2: Bridgett Bell is single, and she is not claiming any dependents.

The Marketplace representative has found Bridgett's information.

• Preparer: “First, who are the covered individuals for this policy?”
• Rep: “Bridgett Bell and Brian Bell.”

Brian Bell is not on your tax return. This is probably an out-of-scope shared policy allocation, but you'll need to talk further with Bridgett to make sure Brian is not a valid dependent or spouse who should be included on the return.

Rather than keeping the Marketplace representative on the line while you question Bridgett further, it might be most efficient to note the information from the 1095-A while you have access to it. Even if the return is out of scope, Bridgett will need the information to complete a return somehow, so you're still being helpful.

Note: Your taxpayer will need some additional details from Form 1095-A that we don't require. These include the Policy Number, the social security number of the other person sharing the policy, and the start and stop dates of the policy indicated on form 1095-A. See Scenarios 3 and 4 for the rest of the process to help Bridgett obtain the needed information.

Scenario 3: Charlie Coleman is a head-of-household filer with one dependent, Chris Coleman.

• Preparer: “Who are the covered individuals on this 1095-A?”
• Representative: “Charlie Coleman and Chris Coleman.”
• Preparer: “And are the amounts in Column A the same for all 12 months of the year from January through December?”
• Rep: “No. It changes in October.”
• Preparer: “So, from January through September, Column A is what?”
• Rep: “$565.25”
• Preparer: “For January through September, Column A is $565.25.”
• Rep: “Correct.”
• Preparer: “And then in October it changes to what?”
• Rep: “$495.80”
• Preparer: “October through December, the premium in Column A is $495.80.”
• Rep: “Yes.”
• Preparer: “Now is Column B the same for all 12 months?”
• Rep: “Yes, it is $542.87.”
• Preparer: “So, for all 12 months of the year, Column B is $542.87.”
• Rep: “Yes.”
• Preparer: “What about Column C? Is it the same for all 12 months?”
• Rep: “No, it changes in October also.”
• Preparer: “What is the amount in Column C for January through September?”
• Rep: “$443.”
• Preparer: “And what is it for October through December?”
• Rep: “$427. Do you need the totals?”
• Preparer: “No, I think you've given me everything I need to finish this tax return. Thank you for your time; you've been very helpful.”

The representative usually offers to mail the document to the taxpayer at the address on file, and that's a good idea in case the taxpayer doesn't have the form at home.

Scenario 4: The facts are the same as in Scenario 3, except you've confirmed the amounts in Columns A and B are the same for all 12 months of the year.

In this scenario, all you really need are the annual totals on Line 33 of the 1095-A for Columns A, B and C. This greatly shortens the process, but remember to repeat the numbers you are writing down to ensure accuracy.

This explanation may seem repetitive, but it’s important to make sure the numbers you’ve obtained are accurate, and that the representative has understood what you need. The process generally takes less than 20 minutes. While that sounds like a lot of time in an hour-long appointment, in many ways, it beats the alternatives. You can proceed with the return and get it filed for the taxpayer the same day. And the taxpayers recognize that you and your program go above and beyond to help them, which instills both confidence in the knowledge and skills of your preparers and goodwill toward your program.