The IRS has released the final updated Forms 1094-C and 1095-C,and while there aren’t many modifications, there are some changes of note. As you probably already know, Form 1094-C is the Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns and Form 1095-C is the Employer-Provided Health Insurance Offer and Coverage. Both forms are required by applicable large employers for information reporting under the Affordable Care Act. So what has changed? Here is a tip sheet:
. There is no longer a “Qualified Offer Method Transition Relief” as an option among the Certifications of Eligibility. That relief applied for 2015 reporting only.
· A number of clarifying changes has been made in Part III. This includes a clarification that the previously used term, “covered individual,” translates to “individual enrolled in coverage, including the employee.”
· Part III’s headers for Columns b and c clarify that a TIN other than SSN may be used, where, in 2015, only SSN was identified. On Line 15, “Employee Share of Lowest Cost Monthly Premium” has changed to “Employee Required Contribution.” On Line 16, “Applicable Section 4980H Safe Harbor Code” has changed to “Applicable Section 4980H Safe Harbor and Other Relief.”
· Instructions for Recipients on the 2016 version provide clarifying language to the 2015 version. Line 14 adds: “(If you received an offer of coverage through a multi-employer plan due to your membership in a union, that offer may not be shown on line 14.)”
· Under Code 1A, the specific dollar amount (for 2015) is replaced with what would constitute 9.5% of the 48 contiguous states single federal poverty line with the term “adjusted.”
· Under Code 1G, the sentence has been modified from 2015 to read: “This code will be entered in the All 12 Months box or in the separate monthly boxes for all 12 calendar months on line 14.”
· Code 1L is a removed option. This code previously represented if the employer claimed “Qualifying Offer Transition Relief.” The 2016 version removes that relief.
· Code 1J is a new code: Minimum essential coverage providing minimum value offered to you; minimum essential coverage conditionally offered to your spouse, and minimum essential coverage NOT offered to your dependent(s).
· Code 1K is a new code: Minimum essential coverage providing minimum value offered to you; minimum essential coverage conditionally offered to your spouse, and minimum essential coverage offered to your dependent(s).
· On Line 15, a modification has been made to include the addition of new codes 1J and 1K and to note that “For more information, including on how your eligibility for other health care arrangements might affect the amount reported on line 15, see IRS.gov.” Note, the terminology of Line 15 replaces “Employee Share of Lowest Cost Monthly Premium” in favor of the new “Employee required contribution.” However, the content appears to be the same.
· On Line 16, “None of this information affects your eligibility for the premium tax credit” has been replaced with new language: “Other than a code 2C which reflects your enrollment in your employer’s coverage, none of this information affects your eligibility for the premium tax credit.”
· Another page as been added for additional covered individuals.
Here are links to view the new forms and final instructions:
For more information, visit IRS.
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