The IRS has released draft versions of the Forms 1094-C and 1095-C and instructions that employers will use in early 2017 to report on health coverage offered in the 2016 calendar year.
Who is Required to Report
Under the Affordable Care Act, applicable large employers(“ALEs”)–generally those with 50 or more full-time employees, including full-time equivalent employees–use Forms 1094-C and 1095-C 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.
2016 Draft Forms and Instructions
The following draft forms are now available for 2016:
The 2016 Draft Instructions for Forms 1094-C and 1095-C are also now available. Among other items, the draft instructions clarify:
- The reporting rules which require employers who are Members of an “Aggregated ALE Group”–a group of ALE Members treated as a single employer under the Internal Revenue Code–to file Forms 1094-C and 1095-C, even if the ALE Member has fewer than 50 full-time employees of its own;
- The indicator codes that should be used to report offers of COBRA continuation coverage on lines 14 and 16 of Form 1095-C; and
- The definitions of “full-time employee” and “Employee Required Contribution” for purposes of Forms 1094-C and 1095-C reporting.
Visit our Information Reporting section for more on these requirements.