Smart Benefits: New ACA Reporting Draft Forms & Instructions Released
Monday, August 29, 2016
Last month, the IRS released draft Forms 1094-C and 1095-C, and on August 1, 2016, published draft instructions for completing the forms for the 2016 tax year.
The forms require applicable large employers to report information about offers of health insurance coverage to full-time employees and the provision of minimum essential coverage during the reporting year. Employers who provide minimum essential coverage under self-insured plans must also report this information for each individual covered under the employer’s self-insured plan.
While the draft forms for tax year 2016 and related instructions are similar to the current versions, according to the IRS, they feature some changes, including:
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Form 1094-C:
o Line 22, box B is designated “Reserved.” The Qualifying Offer Method Transition Relief is not applicable for 2016.
o In Part III, column (b), “Section 4980H” was inserted before “Full-Time Employee Count for ALE Member” to remind filers that the section 4980H definition of “full-time employee” applies for purposes of this column, not any other definition that an ALE Member may use for other purposes.
Form 1095-C:
o The language “Do not attach to your tax return. Keep for your records.” Was inserted under the title of the form to inform the recipient that Form 1095-C should not be submitted with the return.
• Changes to Codes
o Code 1I for Form 1095-C, line 14, and code 2I for Form 1095-C, line 16, are no longer applicable and have been reserved.
o New codes 1J and 1K, addressing conditional offers of spousal coverage, have been added for Form 1095-C, line 14.
• Transition Relief. Several forms of transition relief were available to employers for 2015, but only limited transition relief continues in 2016. References to transition relief that applied only in calendar year 2015 have been removed. Descriptions of the remaining forms of transition relief have been amended to clarify for which months in 2016 the transition relief applies.
The draft forms and instructions are not final. Once finalized, for calendar year 2016, Forms 1094-C and 1095-C must be filed by February 28, 2017, or March 31, 2017, if filing electronically.
Rob Calise is the Managing Director, Employee Benefits. of Cornerstone|Gencorp, where he helps clients control the costs of employee benefits by focusing on consumer driven strategies and on how to best utilize the tax savings tools the government provides. Rob serves as Chairman of the Board of United Benefit Advisors, and is a board member of the Blue Cross & Blue Shield of RI Broker Advisory Board, United HealthCare of New England Broker Advisory Board and Rhode Island Business Healthcare Advisors Council. He is also a member of the National Association of Health Underwriters (NAHU), American Health Insurance Association (AHIA) and the Employers Council on Flexible Compensation (ECFC), as well as various human resource associations. Rob is a graduate of Bryant University with a BS in Finance.
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