Draft Instructions for Form 1094/1095-B/C

Posted by BAS - 07 September, 2017

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The IRS released draft instructions for the 2017 Form 1094 and 1095 B and C Forms for reporting under the Affordable Care Act. Form 1095-B/C is required to be furnished to individuals by January 31, 2018. Form 1094-B/C is required to be transmitted to the Internal Revenue Service by February 28, 2018 (if furnishing on paper) and by March 31, 2018 if sending electronically. In prior years, the IRS extended these deadlines.

The Forms are used to report certain information to the IRS and to taxpayers about individuals who are covered by minimum essential coverage and therefore are not subject to the individual shared responsibility payment. They are also used to document a large employer’s proper offer of health coverage.

The C series of forms are used by ALEs to report information about full-time employees and covered individuals. The B series of forms are used by small employers with self-funded health coverage (as plan sponsor) and by insurance companies to report information about covered individuals. The B series of forms may also be used by larger plan sponsors (acting, in a way, as an insurance company) to report coverage information.

  • ALE with Fully Insured Coverage- Employer sends Form 1095-C to its full-time employees and transmits information to the IRS using Form 1094-C. The insurance company sends Form 1095-B to covered individuals.
  • ALE with Self-Insured Coverage- Employer sends Form 1095-C to full-time employees and to covered individuals. Employer transmits information to IRS using Form 1094-C.
  • Small Employer with Fully Insured Coverage- Insurance company takes care of all reporting using Forms 1094-B and 1095-B.
  • Small Employer with Self-Funded Coverage- Employer sends Form 1095-B to covered individuals and transmits information to the IRS using Form 1094-B.

A copy of the draft instructions for the B Forms can be found by clicking here and for the C Forms can be found by clicking here.

The instructions remove the discussion of transition relief. Few other changes were made from the 2016 instructions.

Topics: Health Care Reform (ACA)


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