IRS Publishes 2016 Draft Forms for ACA Reporting

With the first ACA reporting deadlines for employers in the rearview mirror, the IRS has released draft forms for 2016. These drafts, if finalized, will be used when employers file in 2017.

The deadlines for reporting of 2016 health coverage are expected to return to the original dates:

  • Deadline to distribute forms to employees and covered individuals will be January 31, 2017
  • Deadline to file paper forms with the IRS will be February 28, 2017
  • Deadline to file electronically with the IRS will be March, 31, 2017.

The draft forms offer few changes from the 2015 forms. Of note, the line 14 code series reflects wording changes in a few codes and new codes 1J and 1K. These new codes discuss conditional offers of coverage to spouses.

Also, the “Plan Start Month” box on Form 1095-C will continue to be optional for 2016.

Draft instructions for employers to complete the forms have not been issued at this time.

Filing for 2016 will reflect several differences that we will expect to see reflected in the instructions to complete the forms. Chief among these is that employers will be required to offer minimum essential coverage to at least 95% of full-time and full-time equivalent employees to avoid the A “no offer” penalty. Transition relief was available for the 2015 coverage year that required an offer to 70% of employees to meet the requirement to offer coverage.

Here are the links to review the draft forms:

Form 1094-C  —  https://www.irs.gov/pub/irs-dft/f1094c–dft.pdf

Form 1095-C —  https://www.irs.gov/pub/irs-dft/f1095c–dft.pdf.

Early releases of all draft forms are at www.IRS.gov/draftforms.