Final Forms for 2017 ACA Reporting Released

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Posted in: Commercial Insurance, Compliance, Employee Group Benefits, Human Resources

On September 28, 2017, the Internal Revenue Service (IRS) released final 2017 forms for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.

Final instructions for 2017 were released in early October. The 2017 forms are substantially similar to the 2016 versions, except that sections related to expired Section 4980H Transition Relief were removed.insurance, horst insurance, aca, final forms, aca reporting

Action Steps

Employers should become familiar with the revisions to the forms, and prepare to file these final versions in early 2018.

Background

The Affordable Care Act (ACA) created reporting requirements under Code Sections 6055 and 6056. Under these rules, certain employers must provide information to the IRS about the health plan coverage they offer (or do not offer) or provide to their employees. Each reporting entity must annually file all of the following with the IRS:

Reporting entities must also furnish related statements (Form 1095-B or 1095-C, or a substitute form) to individuals.

Forms must generally be filed with the IRS no later than February 28 (March 31, if filed electronically) of the year following the calendar year to which the return relates. Individual statements must be furnished to individuals on or before January 31 of the year immediately following the calendar year to which the statements relate.

2017 Forms and Instructions

The 2017 forms and instructions are substantially similar to the 2016 versions. However, note the following changes:

In addition, a prior draft version of Form 1095-C for 2017 clarified that the “Plan Start Month” box in Part II of Form 1095-C will remain optional for 2017. The instructions for Forms 1094-C and 1095-C indicate that this box may be mandatory for the 2018 Form 1095-C.

Additional Resources

The 2016 versions of these forms are also available on the IRS website:

These forms must have been filed with the IRS no later than February 28, 2017 (March 31, 2017, if filing electronically). However, the IRS extended the due date for furnishing individual statements for 2016 an extra 30 days, from January 31, 2017, to March 2, 2017. The IRS does not anticipate extending the filing or furnishing deadlines for 2017 reporting.

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.

The IRS also previously released:

More Information

Please contact Horst Insurance for more information on reporting under Code Sections 6055 and 6056.