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IRS Releases 2016 Draft Instructions for Forms 1094-C and 1095-C

Aug 18, 2016

HR360, Inc.
August 10, 2016

Forms Due in 2017, Used to Report ACA Compliance & Offers of Health Coverage

The IRS has released the 2016 Draft Instructions for Forms 1094-C and 1095-C to help employers prepare for calendar year 2016 information reporting. Employers are required to report in early 2017 for calendar year 2016.

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.

Key Changes for 2016 Reporting
Among other changes, the 2016 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.

2016 Draft Forms
The following draft forms are also now available for 2016:

Visit our Information Reporting section for more on these requirements.

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