The IRS has released draft versions of the Health Coverage Reporting 2016 Forms 1094-B, 1095-B, 1094-C, and 1095-C that employers and insurers will use in early 2017 to report on health coverage offered in the 2016 calendar year.
The Affordable Care Act (ACA) requires insurers, self-insuring employers, and other parties that provide minimum essential health coverage to report information on this coverage to the IRS and to covered individuals using Forms 1094-B and 1095-B. Applicable large employers (generally those with 50 or more full-time employees, including full-time equivalents) are also required to report information to the IRS and to their employees about their compliance with the employer shared responsibility provisions (“pay or play”) and the health care coverage they have offered using Forms 1094-C and 1095-C.
The following draft forms are now available for 2016 Health Coverage Reporting:
Key Changes for 2016
Notable Health Coverage Reporting changes from the 2015 forms include:
The “Qualifying Offer Method Transition Relief” box is no longer on line 22 of Form 1094-C, as that transition relief was only available to employers with calendar year plans for 2015 reporting.
Two new line 14 codes (codes 1J and 1K) will be available on Form 1095-C to reflect conditional offers of coverage to an employee’s spouse.
The “Instructions for Recipient” section of Form 1095-B now says that if the recipient or a member of his or her family received employer-sponsored coverage, that coverage may be reported on a Form 1095-C rather than a Form 1095-B. These instructions also tell recipients that certain lines may be left blank even if the recipient received employer-sponsored coverage.
Providers that file 250 or more information returns during the calendar year must file the returns electronically. Transmittal of Health Coverage Information Returns, with the IRS annually, no later than February 28 (March 31 if filed electronically)
The information furnished and Health Coverage Reporting is used by individuals and the IRS to verify the months, if any, in which individuals were covered by minimum essential coverage and, therefore, have satisfied the individual shared responsibility requirement of section 5000A of the Internal Revenue Code.
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This article should not be construed as legal advice and is intended for general information purposes only. If you have any questions regarding this article, you should consult your legal counsel.