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1094 /1095 Draft Forms Released


The IRS released draft versions of the Forms 1094-B, 1094-C, 1095-B and 1095-C for 2017 tax year reporting under the Affordable Care Act (ACA).  The only noteworthy change is the removal of the box for “Section 4980H Transition Relief" on line 22 of Form 1094-C, since it no longer applies.

Applicable Large Employers (ALEs - generally those with 50 or more employees) and employers who provide self-insured health plans are subject to reporting requirements.  ALEs must report whether (and to what extent) coverage is offered to full-time employees as explained on IRS webpage.  To determine whether you are an ALE, please see the IRS webpage for calculation and examples.  Additionally, employers who provide self-insured health coverage (regardless of size) must identify individuals covered under the plan; see IRS webpage for more information.

Although Congress has attempted to make changes to the law, as of now ACA provisions are still in play, and employers should maintain compliance to avoid significant potential penalties.  For filings made in 2017, the penalty per late or incorrect return/statement was $260 subject to a $3,193,000 calendar year maximum.  Penalties double if reporting to both the individual and the IRS is late or incorrect.

The general deadline for 2017 reporting to individuals is January 31, 2018 and to the IRS by February 28, 2018 (or March 31, 2018 if filing electronically).  Stay tuned for additional details and draft instructions from the IRS.

VIEW Form 1094-B

VIEW Form 1094-C

VIEW Form 1095-B

VIEW Form 1095-C