The bad news – for some — is that the ACA, including employer reporting, is still here despite the months of Congressional activity. The good news – for many employers subject to the ACA’s employer reporting requirements — is that the reporting forms are pretty much unchanged from last year. Few changes mean that many of the lessons learned over the past years don’t have to be jettisoned.
And, it’s not too soon for employers to prepare for filing of Forms 1094-C and 1095-C. For calendar year 2017, Forms 1094-C and 1095-C must be filed with the IRS by February 28, 2018 on paper or April 2, 2108, if filing electronically. Forms must be furnished to employees by January 31, 2018.
Forms and Instructions
The 1095-B Form for 2017 can be found here.
Instructions for Forms 1094-B and 1095-B can be found here.
The 1094-C Form for 2017 can be found here.
The 1095-C Form for 2017 can be found here.
Instructions for Forms 1094-C and 1095-C can be found here.
Q&A about Information Reporting by Employers can be found here.
Employers wishing to use a substitute Form 1094-C or 1095-C can find guidance in Publication 5223.
Tips and Reminders
Here are some reminders and tips on completing these forms.
Employers planning to use a vendor need to make decisions now, if they haven’t already. Time is needed to understand how information must be presented to the vendor and to allow time for preparation, testing and the like.
Box 10 of Form 1095-C asks for the employer’s contact number. It’s important that this number connects to a person who understands the employer’s reporting process or that the person answering the phone knows who to contact internally.
Statements must be furnished on paper by mail or hand delivered unless there is affirmative consent by the recipient to receive the statement electronically. Information on consent to receive electronic statements can be found here.
Consent to receive statements electronically should address the duration of the consent. If consent forms used last year didn’t specify that consent would be ongoing, new consent may be required for this year.
The Federal Poverty Line Safe Harbor maximum monthly employee contribution for 2017 is $95.93.
There is no specific code to enter on Form 1095-C if an employee has waived coverage. When an employee has waived coverage it behooves the employer to complete line 16 with a safe harbor code, if any applies.
Information reporting penalties may apply for failing to comply. For example, failure to file a correct return is $260 per return. Special rules apply for penalties due to intentional disregard.