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IRS Releases ACA Reporting Updates, Including 2017 Forms 1094/1095-B and Instructions

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EBIA  

2017 Forms 1094-B and 1095-B; 2017 Instructions for Forms 1094-B and 1095-B

The IRS has released final 2017 Forms 1094-B and 1095-B (B Forms) and related instructions. As a reminder, the B Forms are filed by providers of minimum essential coverage (MEC) (including insurers, self-insured multiemployer plans, and government-sponsored programs) to report coverage information in accordance with Code § 6055 added under the Affordable Care Act (ACA). Applicable large employers (ALEs) file Forms 1094-C and 1095-C (C Forms), and ALEs with self-insured health plans satisfy Code § 6055 by reporting enrollment information on Part III of Form 1095-C (see our Checkpoint article). There are no substantive changes to the B Forms for 2017, and the instructions are also mostly unchanged. Insurers are again encouraged, but not required, to use the B Forms to report coverage in catastrophic health plans enrolled in through an Exchange. The 2018 filing deadlines are noted: January 31 to furnish Form 1095-B to individuals; and February 28 for paper filings (April 2 for electronic filings) transmitted to the IRS with Form 1094-B. (Electronic filing through the IRS’s Affordable Care Act Information Returns (AIR) Program system is mandatory for those transmitting 250 or more Forms 1095-B or 1095-C.) For paper filers, the instructions indicate that the filing can be divided into “conveniently sized” packages, so long as a copy of the filer’s Form 1094-B transmittal is included with each package.

The IRS has also updated the following ancillary documents that provide essential information for electronic filers of the B Forms and C Forms:

  • Publication 5164, Test Package for Electronic Filers of Affordable Care Act (ACA) Information Returns (AIR) (Processing Year 2018). This publication provides detailed technical information about the testing system for electronic filers. Only new users of the electronic filing system need to test. Therefore, software developers who passed testing for a prior year do not have to retest for 2017 forms that will be processed in 2018. And transmitters must complete communication testing to demonstrate their ability to successfully send returns and receive the acknowledgment file only in the first year that they will transmit forms. The IRS continues to emphasize that the testing system should not be used to submit actual individual or business names or taxpayer identification numbers, since the testing environment is not secure. Testing will begin in early November.
  • Publication 5165, Guide for Electronically Filing Affordable Care Act (ACA) Information Returns for Software Developers and Transmitters (Processing Year 2018). This publication outlines the communication procedures, transmission formats, business rules, and validation procedures for electronically transmitted information returns. The list of error codes and messages has been updated for the 2018 processing year. The publication also explains the process for requesting extensions of the filing deadlines, which will be available starting in January 2018.
  • Publication 5258 Affordable Care Act (ACA) Information Returns (AIR) Submission Composition and Reference Guide. This publication provides technical guidance about composing and successfully transmitting compliant submissions to the IRS. Additional guidelines are provided for replacement submissions. Tables provide the definitions for data elements in each line of the B Forms and C Forms.

Additional technical information can be found on the recently updated IRS webpage addressing Tax Year 2017 Affordable Care Act Information Returns (AIR) Known Issues, Crosswalks, Schemas and Business Rules.

EBIA Comment: As it prepares for the third year of processing ACA information returns, the IRS seems to have settled on most of its information requirements and filing processes, since the forms and publications are largely unchanged from last year. Those interested in electronic filing may wish to note the IRS’s creation of a new webpage to report the operational status of the AIR program. The IRS is also using this new webpage to communicate the latest AIR program updates. For more information, watch for the 2017 update to EBIA’s Form 1094/1095 Workbook, including Sections IV (“Easy as ABC: Basics of the Reporting Forms”), IX (“Furnishing Employee Statements”), and X (“Filing With the IRS”). See also EBIA’s Health Care Reform manual at Section XXXVI.C (“Information Reporting of Minimum Essential Coverage (Insurers and Employers That Self-Insure)”). You may also be interested in our upcoming webinar “Get Ready for Form 1094/1095 Reporting for 2017” (live on 11/15/2017).

Contributing Editors: EBIA Staff.

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