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IRS Releases Draft Forms for 2017 ACA Reporting

 September 7 2017     Diane Cross

In anticipation of upcoming reporting requirements for Section 6055 and 6056 per the Affordable Care Act, the IRS has released draft forms and instructions.  Employers will notice that the 2017 forms and instructions are very similar to 2016, with clarification on some information and minor changes for items that no longer apply.  While employers should become familiar with any revisions to the draft forms, the draft forms are provided as a courtesy and are not to be used or relied upon with filing.   

Draft Forms and Instructions:

Summary of changes include:

  • With no section 4980H transition relief is available for 2017, references to the Section 4980H transition relief has been deleted from the form and instructions.
  • Multiemployer interim rule relief and reporting remains in effect for 2017 reporting for ALEs with multiemployer plans.
  • Items that have been adjusted for inflation (e.g. affordability percentage – 9.69 percent for 2017) have been updated.
  • Clarification note (not a change) is added in the instructions for Form 1095-C, line 16, “There is no specific code to enter on line 16 to indicate that a full-time employee offered coverage either did not enroll in the coverage or waived the coverage.”
  • IRS ACA Tax Provisions Questions and Answers website provides ALE members with additional information, including reporting examples.

New for Forms 1094-B and 1095-B, health insurance issuers and carriers are encouraged (but not required) to report coverage in catastrophic health plans enrolled in through the Marketplace for months in 2017.

As a reminder, Form 1095-C (or 1095-B if applicable) must be delivered to employees by January 31, 2018, and Forms 1094-C and 1095-C (or 1094-B and 1095-B if applicable) due to the IRS by February 28, 2018 if paper filing or April 2, 2018 if electronic filing.  Paper filing is only available for employers with fewer than 250 returns. 

Please contact your HORAN representative with questions.