By - July 15, 2016

Form 1095-C and Form 1094-C Drafts Released for 2016

Draft ACA forms

The Internal Revenue Service (IRS) has released draft versions of Forms 1095-C and 1094-C for the 2016 tax year. While much of the content looks identical to the 2015 versions of the forms, the IRS has not provided draft for the forms. This means that there will need to be some interpretation of the changes, and details on some of the codes and fields provided are still unknown.

Here’s a rundown on what we do know that’s different for the two forms.

Form 1095-C

  • Language at the top of the form now alerts taxpayers that the form does not need to be attached to their tax records. We believe that this was in response to the confusion over whether or not employees needed to provide the document when filing their tax returns.
  • Line 14 codes (series 1) are expanded to support plans where Minimum Essential Coverage (MEC) and Minimum Value (MV) are offered to the employee, but conditional offers of coverage are offered to the spouse and/or dependent. A full definition of “conditional offers” is not yet available, but we suspect these are to alert the IRS to employers who require employees to certify their spouse do not have an offer from their employer in order to have coverage, usually with a surcharge. Code 1I, which was transition relief for 2015 non-calendar year plans, is listed as “reserved.”
  • Under Covered Individuals (Part III), the term “or other TIN” is called out. We believe this is due to the struggle many employers had with non-citizen employees who had a TIN but not a SSN or dependents.

Form 1094-C

  • As expected, “Qualifying Offer Method Transition Relief for 2015” is now listed as “reserved” while other Line 22 “Certifications of Eligibility” remain.

See 1095-C and 1094-C Forms

1095-C IRS Form
1094-C IRS Form

If you have questions about these forms or about ACA compliance, contact us for more information.

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