IRS Releases Final 2016 Forms 1094 and 1095
The Internal Revenue Service (IRS) has released the final forms and instructions for Forms 1094 and 1095 for calendar year 2016 reporting. Employers are required to report in early 2017 for calendar year 2016.
Who is Required to Report
Applicable large employers (ALEs)—generally those with 50 or more full-time employees, including full-time equivalents (FTEs)— must use Forms 1094-C and 1095-C to report information to the IRS and to their full-time employees about their compliance with the employer shared responsibility provisions (“pay or play”) and the health care coverage they have (or have not) offered in a calendar year. Note that ALEs who do not offer health coverage must report to the IRS on the applicable forms.
Forms 1094-B and 1095-B are used by insurers, self-insuring employers, and other parties that provide minimum essential health coverage (regardless of size, except for large self-insuring employers) to report information on this coverage to the IRS and to covered individuals.
Employers subject to both reporting provisions (generally self-insured employers with 50 or more full-time employees, including FTEs) will satisfy their reporting obligations using Forms 1094-C and 1095-C.
2016 Forms and Instructions
The following calendar year 2016 reporting forms and instructions are now available:
- Form 1094-C (transmittal)
- Form 1095-C
- Form 1094-B (transmittal)
- Form 1095-B
Information Reporting Deadlines
ALEs must furnish a Form 1095-C to each of its full time employees by January 31, 2017.
Forms 1094-C and 1095-C are also required to be filed with the IRS by February 28, 2017 (or March 31, 2017, if filing electronically).
Filers of Form 1095-B must furnish a copy of that form to the person identified as the “responsible individual” by January 31, 2017. The responsible individual is the person who, based on a relationship to the covered individuals, the primary name on the coverage, or some other circumstances, should receive the statement. Forms 1094-B and 1095-B are also required to be filed with the IRS by February 28, 2017 (or March 31, 2017, if filing electronically).
Please be advised that Forms 1095-B and 1095-C must be electronically filed if the reporting entity is required to file at least 250 of the specific form.
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Please contact Lucia Fan, Senior Consultant regarding any ACA compliance questions.
Lucia Fan, GBA
Certified Health Care Reform Specialist ®
703-938-7550 x 6