The Internal Revenue Service (IRS) has released 2016 draft forms regarding the employer reporting requirements under the Affordable Care Act. While instructions for the 2016 forms have not yet been released (Update: The IRS has released Draft Instructions for the forms as of 8/11/2016), it is advisable for employers to become familiar with the planned revisions to the forms.
Links to the 2016 Draft Forms
For the majority of our clients, Forms 1094-C and 1095-C will be used to report on 2016′s data. Below are links to the 2016 draft forms:
These forms are to be used by applicable large employers to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by applicable large employers who sponsor self-insured plans.
Noticeable Changes to the 2016 Forms
- Tax Filing Information for Employees on Form 1095-C: A line has been added to the top of the form stating “Do not attach to your tax return. Keep for your records.” While many employees were aware that these forms would play a role in their tax filing process for 2015, this instruction will perhaps prevent an extra step that was taken by some this year.
- New Offer of Coverage of Codes: Two new codes, 1J and 1K, were added that may be used for situations where health insurance coverage was “conditionally offered to the employee’s spouse”.
- Plan Start Month: Many expected that this field, which was optional for the 2015 filing, would be required in 2016. However, the draft Form 1095-C document highlights that this field will once again not be required.
- Part III of Form 1095-C: This section, which should only be filled out by groups that offer self-insured plans, has been updated to clarify that the actual employee covered by the plan should also be listed in this section, in addition to any covered dependents.
I hope that you find this brief overview helpful. For additional information about some of the other changes on these draft forms, we encourage clients to visit the CBGconnect portal and download our Compliance Bulletin on this topic.
If you have any questions in the meantime about how your company can meet its ACA reporting requirements, please contact our team at 781-759-1222.