In case you haven't heard, the IRS has issued the final 2017 forms for Affordable Care Act (ACA) reporting as required under Code Sections 6055 and 6056.  If you're one of the employers required to provide information on the health coverage you do or do not offer, here are some helpful links and deadlines to keep in mind.

  • Forms 1094-C and 1095-C are to be used by applicable large employers (ALE) to report under Section 6056, as well as for combined Sections 6055 and 6056 reporting by ALEs who sponsor self-insured plans.  Instructions can be found here.  
  • Forms 1094-B and 1095-B are to be used by entities reporting under Section 6055, including self-insured plan sponsors that are not applicable large employers (ALEs).  Instructions can be found here.

The 2017 forms are very similar to the 2016 versions.  The new forms, however, do not include the sections related to Section 4980H Transition Relief, which has expired. 

As a reminder, each reporting entity must annually file with the IRS a separate statement (Form 1095-B or Form 1095-C) for each individual who is provided with minimum essential coverage (for providers reporting under Section 6055), or for each full-time employee (for ALEs reporting under Section 6056); and a transmittal form (Form 1094-B or Form 1094-C) for all of the returns filed for a given calendar year.  Reporting entities must also furnish related statements (Form 1095-B or 1095-C, or a substitute form) to individuals.

The due dates for 2017 reporting in 2018 are:

  • March 2, 2018 (extended from Jan. 31, 2018 in IRS Notice 2018-06): Deadline to furnish 2017 Form 1095-C (or 1095-B, if applicable) to employees and individuals.
  • Feb. 28, 2018 for paper filing (April 2, 2018 for electronic filing): Deadline for paper filing of all 2017 Forms 1095-C and 1095-B, along with transmittal form 1094-C or 1094-B, with the IRS.  (April 2 is the first business day following the usual due date of March 31 for electronic filing).

According to the IRS, information returns under Sections 6055 and 6056 may continue to be filed after the filing deadline (both on paper and electronically). Employers that missed the filing deadline should continue to make efforts to file their returns as soon as possible.

For additional information, the IRS previously released a few Q&As on Section 6055 and 6056, as well as on employer reporting using Form 1094-C and Form 1095-C.

This blog is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.