On August 6, the IRS released yet another draft of forms 1095-C and 1094-C to help Applicable Large Employers prepare for the first year of mandatory reporting.

For the most part, since the last update in June, there are few changes to report. Specifically, the updated instructions note:

1094-C Revisions

1. The IRS moved line 19 (denotes whether or not the form is an Authoritative Transmittal) from Part II of the form to Part I. For all intents and purposes, this is a cosmetic change.
2. On Part III, line 23, column b (number of full-time employees), employers are now able to enter a number into the “all 12 months” box, which had previously been greyed-out. Of note, for employers who qualify for the “98% Offer Method” by selecting box “b” in line 22, they do not have to complete column “b” in Part III. (This is more than merely offering 98% of full-time employees coverage! Coverage must be offered to employees and dependents)

Related Blog: How To Complete the 1094-C

1095-C Revisions

1. In Part II, there is now a place to identify the month (January = 01, February = 02, etc.) in which the employer’s plan year begins. This would be the month in which an employer would begin their coverage if offered benefits during the employer’s standard enrollment period. If there is more than one plan start year, as in the case when an employer changes providers mid-plan year, the employer will use the earlier plan start month of the 2. An employer will never enter “00”.

Related Blog: Everything You Need to Know About 1095-C Reporting

The guidelines include further information on submitting corrections for 1094-C and 1095-C forms. For a PDF of the August 5 Updated IRS reporting guidelines, click here.

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