ACA Form 1095-C Updated for 2016 Filing

Even when it’s not filing season, the IRS makes sure to keep itself busy. Just last month, they released draft Forms 1094-C and 1095-C and published draft instructions for completing them for the 2016 tax year.

While these updates are just drafts, there are already a few changes between the forms you filled out for your 2015 ACA return and the ones you’ll complete for your 2016 return. These changes are likely to stick, however, and once the Forms 1094-C and 1095-C are finalized, they must be e-filed by March 31, 2017.


Form 1094-C Changes

• Box B of Line 22 is designated “Reserved.” The Qualifying Offer Method Transition Relief is not available for 2016.
• In Part III, column (b), “Section 4980H” was added before “Full-Time Employee Count for ALE Member.” This was included to remind filers that “full-time employee,” as defined by section 4980H, applies for purposes of this column. ALE Members may not use another definition of FTEs to complete this column.

Form 1095-C Changes
Underneath the title of Form 1095-C, the reminder, “Do not attach to your tax return. Keep for your records.” was added to inform recipients not to file Form 1095-C with their personal return.

Code Changes

• Code 1I on Form 1095-C, line 14, and Code 2I for line 16 are no longer applicable for the 2016 filing year.
• New codes for addressing conditional offers of spousal coverage, 1J and 1K, have been added for use on Form 1095-C, line 14, if applicable.

Transition Relief Changes
Only limited transition relief will continue for the 2016 tax year. Because several forms of transition relief were available to employers for the 2015 tax year only, references to these forms of relief have been removed from Forms 1094-C and 1095-C.

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