It reminded me of the Abbott and Costello "Who's on First?" routine, except no one was laughing.  https://www.youtube.com/watch?v=sMXgvAGbQGg

Two people having a conversation using terms like AIR, TCC, AATS, XML, Issuer, Transmitter,A2A, SOAP etc. all to figure out who is going to "actually" transmit the ACA data' to the IRS! After 30 minutes, the vendor conceded they will not be filing with the IRS (too much liability) but will prepare the .xml document the IRS requires and the client just has to transmit it to the IRS. This downplays how difficult the IRS transmittal process can be.

The client picked up on this and asked ' Ok, so what do we have to do now?" It didn't get any better. Forget the e-filing deadline of June 30 is almost here.The "all you need to do" answered resembled the process to obtain a license to operate a nuclear plant. First, find 2 Responsible Officials to register to e-file, apply for a Transmitter Control Code (TCC) for a role of Issuer, Transmitter, complete the required AATS Submission testing and be accepted as a filer by the IRS. Completing this on your own will require a significant investment of time and resources, including IT resources which will be needed to meet the specifications the IRS requires. Then you can take the XML file, create an XML manifest with a UUID, MDA Hash,Checksum, time stamp..submit, retrieve errors,resubmit etc. OK enough!  

A simple e-filing solution is at hand!  There is no need for your organization to perform these tasks or obtain your own Transmitter Control Code if another entity will be filing the returns on your behalf. Full disclosure: ACA AIR e-filing is my business, my only business. My advice; don't attempt to do this at home. Let a professional do it for you..and enjoy the summer.   http://www.benefitscape.com/GetStarted/tabid/126/Default.aspx

Not convinced? Full DIY details are here: https://www.irs.gov/for-tax-pros/software-developers/information-returns/affordable-care-act-information-return-air-program