Final ACA Reporting Forms and Instructions for 2016

Oct. 5, 2016 – The IRS has released final 2016 forms for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.

• Forms 1094-B and 1095-B are used by entities reporting under Section 6055, including self-insured plan sponsors that are not applicable large employers (ALEs). Final 2016 versions of these forms and final instructions were released on Sept. 26, 2016.

• Forms 1094-C and 1095-C are used by ALEs to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans. Final 2016 versions of these forms and final instructions were released on Sept. 30, 2016.

Minor changes were made to the forms, including the addition of two new “Offer of Coverage” codes for use on Form 1095-C. The instructions also included some clarifications to existing rules, including changes for certain transition relief provisions that are no longer available, or only available for certain months in 2016.

Employers should become familiar with the revisions to the forms. These final forms and instructions can be used for filing with the IRS in early 2017, for coverage in 2016.

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