Draft 2017 Form 1094-B, Form 1095-B, Form 1094-C, and Form 1095-C
The IRS has issued draft Form 1094/1095 information returns for the 2017 tax year (for filing in early 2018). Forms 1094-B and 1095-B are used by coverage providers to report health plan enrollment as required by Code § 6055. Forms 1094-C and 1095-C are used by applicable large employers (ALEs) to report information relevant to Code § 4980H employer shared responsibility penalties as required by Code § 6056. (ALEs sponsoring self-insured health plans are coverage providers; they satisfy their Code § 6055 obligation by reporting coverage information on Form 1095-C.) The forms also provide information relevant to the individual shared responsibility penalty and premium tax credits.
The draft 2017 forms show few changes from 2016. Here are highlights:
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Form 1094-B. Form 1094-B, which is the transmittal for Form 1095-B, is unchanged.
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Form 1094-C. The only change is removal of the line 22 box for “Section 4980H Transition Relief.” This relief was applicable only to the 2015 plan year; it remained on the 2016 form since some non-calendar-year plans qualified for this relief for months of the 2015 plan year falling in the 2016 calendar year.
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Forms 1095-B and 1095-C. There are no substantive changes on the face of these forms. A new paragraph in the Instructions for Recipients entitled “Additional information” refers recipients to an IRS webpage that provides an overview of the provisions of the individual shared responsibility, employer shared responsibility, and premium tax credits along with contact information for the IRS Healthcare Hotline for questions.
EBIA Comment: We expect the draft instructions to the forms to be issued in the coming weeks, which will provide a more complete picture of reporting for the 2017 tax year. Despite ongoing efforts to repeal, replace, or otherwise change certain provisions of the Affordable Care Act, no changes have yet been made to the reporting requirements. Therefore, coverage providers, ALEs, and their advisors should diligently continue their efforts to prepare for filings for the 2017 tax year. For more information, see EBIA’s Form 1094/1095 Workbook at Sections IV (“Easy as ABC: Basics of the Reporting Forms”), VII (“Form 1094-C: Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns”), and VIII (“Form 1095-C Report/Employee Statement: Employer-Provided Health Insurance Offer and Coverage”). See also EBIA’s Health Care Reform manual at Sections XXXVI.C (“Information Reporting of Minimum Essential Coverage (Insurers and Employers That Self-Insure)”) and XXXVI.D (“Information Reporting of Employer-Sponsored Coverage (Applicable Large Employers)”). You may also be interested in our upcoming webinar “Get Ready for Form 1094/1095 Reporting for 2017” (live on 11/15/17).
Contributing Editors: EBIA Staff.
