It doesn’t seem possible that it’s already time to consider 2016 Affordable Care Act reporting. Drafts of the revised forms 1095-C and 1094-C were released in late July by the IRS. Note the forms for Applicable Large Employer reporting are drafts only, and not for use in filing. Final forms and updated instructions will be released at a later date.
Highlights of the changes to the 1095-C form include:
- Simplification and clarification of instructions;
- Enhanced explanation of the employee required contribution (Line 15);
- Addition of two new indicator codes, 1J and 1K, for conditional offers of minimum essential coverage to spouses. A conditional offer typically occurs if an employer allows enrollment of the spouse only when the spouse does not have access to health insurance through the spouse’s own employer.
Changes to the 1094-C form are minimal: Box 22B (Qualifying Offer Transition Relief) is changed to “reserved,” since the transition relief has expired.
For 2016 reporting, a “good-faith” filing effort will not be sufficient. The IRS will impose a $500 penalty per form for incorrect, inaccurate, or late forms.
The deadlines for 2016 filing are:
- January 31, 2017 – providing a 1095-C to each full-time employee
- February 28, 2017 – furnishing to the IRS paper copies of all 1095-C’s with transmittal form 1094-C
- March 31, 2017 – electronic filing with the IRS of forms 1095-C and transmittal 1094-C. This applies if you must file at least 250 information returns for the year.
To see the new forms: