What Employers Need to Know About the 2017 1095/1094-C
On September 28, 2017, the IRS released the new forms 1095-C and 1094-C to be used for mandatory 2017 reporting.
The 1095-C and 1094-C are used by Applicable Large Employer groups under the Affordable Care Act to fulfill IRS Code Section 6055 and 6056 reporting requirements. In layman’s terms, they communicate:
- To whom did you offer health benefits?
- Was it affordable?
- Did it provide minimum value?
Unless you’re a new ALE in 2017, this should be old-hat by now. Here’s what you need to know for 2017.
So what is different in the 2017 forms?
There are a few new items that we haven’t seen in previous reporting years, but in general the forms and instructions are very close to those of 2016.
As far as the the more dynamic Part II of the 1095-C (Filling in all those nasty codes), you’re looking at the same codes and layout as 2016.
The 1094-C has removed some options in Part II. Given that Transition Relief no longer applies, the form has marked those former options as “Reserved.” These boxes are to go unchecked for 2017 reporting.
Other changes and penalty updates include:
- Additional instructions for 1095-C/B recipients with regard to tax credits and individual mandate penalties
- Updated penalty amounts for failure to file or furnish forms in 2017: $260 per violation up to a maximum amount of $3,218,500
- Line 16 Clarification: The IRS enhanced the 1095-C line 16 instructions to say that there is no specific code for an employee that did not enroll or waived coverage
- Updated instructions on when employers are required to provide corrected 1095-Cs to employees for de minimis errors
- Requirement for returns filed with the IRS specifying that all returns must be printed in landscape format
Reporting deadlines for filing 2017 forms with the IRS are February 28 (March 31, 2017 if filing electronically). The good news is that the IRS extended the deadline for furnishing individual statements to recipients from January 31 to March 2, 2017. Of note, despite extensions in years past, the IRS does not foresee granting an extension for filing or furnishing for 2017 reporting.
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