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IRS Issues Small but Important Changes to ACA Forms


Despite all the "huffing and puffing" by the politicians, the Affordable Care Act is still with us. But that doesn't mean there haven't been changes. The IRS requires the filing of two pairs of forms:

  • Form 1094-B, Transmittal of Health Coverage Information Returns, and 1095-B, Health Coverage.
  • Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage.

The pair you use depends on your particular status and situation.

What will be changing in these two pairs? The good news is, not much. But the changes that have been made are important, and you need to know about them.

Forms 1094-B and 1095-B

According to the IRS, health insurance issuers and carriers are encouraged (but not required) to report coverage in catastrophic health plans enrolled in through the Marketplace for months in 2017.

Forms 1094-C and 1095-C

The IRS explains that several forms of transition relief were available to some employers under section 4980H for 2016. However, no section 4980H transition relief is available for 2017. Therefore, form instructions have been revised to remove discussion of section 4980H transition relief, and Form 1094-C has also been revised. Getting into details: Form 1094-C, line 22, box C is designated "Reserved"; Part III, column (e) is designated "Reserved"; and the entry rows in Part III, column (e) are shaded.

So at least we know that these are all the changes and everything else is set in stone, right? Unfortunately, that is wrong. This continues to be a volatile situation, and there is no guarantee that future regulations won't change filing issues in the coming months. However, we will keep you informed of any future changes and explain to you whether, and how, these current changes affect your company.


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