On September 30th, 2016, the IRS published final versions of Form 1094-C, Form 1095-C, and the final 2016 Instructions. Generally, these forms will be used by employers to report offers of health insurance coverage made to their full-time employees during the 2016 calendar year.
There were only minor changes made to the 2016 version of these forms. For example, two new “Offer of Coverage” codes are included on Form 1095-C, to indicate conditional offers to spouses.
To learn more about the changes made to the 2016 version of these forms, we encourage all clients to download our detailed ACA Compliance Bulletin within the CBGconnect portal. (Need help logging in? Please contact our team at 781-759-1222.)
Who Needs to Report
These reporting requirements generally apply to “applicable large employers” (ALEs). An employer is an ALE for a calendar year if it employed an average of at least 50 full-time employees, including full-time equivalent employees (FTEs), during the previous calendar year.
The Reporting Deadlines
The 2016 ACA employer reporting deadlines are as follows:
- January 31, 2017 (As of 11/18/2016, this deadline has been extended until March 2, 2017): Form 1095-C due to employees (to be postmarked, if mailed, or sent by email if applicable conditions are met)
- February 28, 2017: Forms 1094-C and 1095-C due to the IRS if filing on paper
- March 31, 2017: Forms 1094-C and 1095-C due to the IRS if filing electronically
Any employer filing 250 or more forms must file their returns electronically, unless the employer obtains a waiver.
How to Comply
As was the case with the 2015 reporting, we recognize that many of our clients will be using a third-party (such as their payroll vendor or HRIS vendor) to handle the form creation, distribution, and filing. If you need assistance during that process, please reach out to our team.
We will once again be offering a service to produce these forms for clients that require an alternative solution. Please contact us as soon as possible if you would like to learn more about that option. You may reach our team at 781-759-1222.