Form 1095-C Changes for the 2016 Tax Year

It’s almost time to start filing those ACA Forms for 2016!

And for all you applicable large employers (ALEs) out there planning to file Form 1095-C, have we got some news for you:

Form 1095-C is going through a few changes for the 2016 tax year, specifically to the code series used for lines 14 and 16.

Code Series 1 Changes
On line 14 of Form 1095-C, filers use Code Series 1 to indicate information about the coverage they offered to their employees. Last year, this series was coded 1A through 1I for each option, but for 2016 codes 1J and 1K have been added.

So it’s important to note that since code 1I only applied for 2015 transitional relief options, it’s been marked as “reserved” by the IRS and should not be used on any future 1095-C Forms.

The new codes, codes 1J and 1K represent the following scenarios:

• Code 1J: Minimum essential coverage (MEC) providing minimum value (MV) was offered to the employee; at least MEC was conditionally offered to the employee’s spouse; nothing was offered to the employee’s dependent(s).
• Code 1K: MEC providing MV was offered to the employee and his/her dependent(s); at least MEC was conditionally offered to the employee’s spouse.

Code Series 2 Changes
On line 16 of Form 1095-C, filers use Code Series 2 to indicate the safe harbor relief that applies to the employee’s scenario, if applicable. Similar to Code Series 1, Code Series 2 initial had codes for 2A through 2I to describe different safe harbor relief options. This year and for future years, code 2I has been “reserved” by the IRS and may no longer be used as it only applied to tax year 2015.

Deadline Changes
Initially, the ACA Forms deadlines were the same as other information return deadlines:

• January 31, recipient/employee copies must be mailed out
• February 28/29, IRS copies that are being paper filed must be mailed
• March 31, IRS copies that are being e-filed must be transmitted

However, last year, the IRS extended the deadlines to give filers a bit of a break with the new forms. That timeline looked like this:

• March 31, 2016: recipient/employee copies must be mailed out
• May 31, 2016: IRS copies that are being paper filed must be mailed
• June 30, 2016: IRS copies that are being e-filed must be transmitted

This year, for 2016 tax year filing, the deadlines look like this:

• February 28, 2017: IRS copies that are being paper filed must be mailed
• March 2, 2017: recipient/employee copies must be mailed out
• March 31, 2017: IRS copies that are being e-filed must be transmitted

Stay tuned with ExpressACAForms for all of your up-to-date ACA information! And don’t forget to sign up with us to e-file your ACA Forms accurately and on time!