Over the past two months, the IRS has gradually rolled out ACA reporting forms for 2016. So far? 1094-B and 1095-B have been changed, as well as 1094-C and 1095-C. While the changes may be minimal to some, it’s clear both the ACA and the IRS have listened to the concerns of employers and individuals and made some necessary modifications to the forms. Most of the changes are found in Form 1095-C aka the Employer-Provided Health Insurance Offer and Coverage forms. Here are a few spoiler alerts:
Qualifying Offer Method Transition Relief For 2015 for Form 1095-C has been changed to a “Reserved” line (Line 14 Code 1 I). This is also true for Form 1094-C’s Line 22 Option B.
In Part II of Form 1095-C, the start month for the plans will once again be optional.
Form 1095-C allows for SSN or TIN for identification (Part III, Column B).
If there is no SSN/TIN available for Form 1095-C, a DOB is still available (Part III, Column C).
Line 14 includes new codes 1J and 1K, both regarding minimum essential coverage for spouses. However, 1J is for coverage not offered to dependents, 1K is for coverage offered to them.
To view the new IRS 2016 form drafts, here are PDF documents:
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