As part of the Affordable Care Act (ACA), new reporting requirements for 2016 have been created by the Internal Revenue Service (IRS) under Code Sections 6055 and 6056 for certain employers. These forms are required by the IRS from certain employers, and they concern health plan coverage that employers do (or do not) provide for their employees.
Forms 1094-B and 1095-B are used by employers reporting under Section 6055. Forms 1094-C and 1095-C are used by employers reporting under Section 6056, and by employers with combined Section 6055 and 6056 reporting. Be sure to take a look at the final instructions for Forms 1094-B and 1095-B provided by the IRS as well as final instructions for Forms 1094-C and 1095-C if these forms apply to you.
There are a few key changes to these updated forms, including:
- Waivers from electronic filing. New instructions state that employers are encouraged to file Form 8508 requesting a waiver at least 45 days before the due date of the return, and no later than the return’s due date.
- Reporting penalties. There are adjusted penalty amounts if an employer fails to file returns or provide statements. The adjusted penalty amount is $260 per violation, with a maximum of $3,193,000.
- Taxpayer Identification Number (TIN). Forms 1095-B and 1095-C now clarify that employers can report a Taxpayer Identification Number instead of a Social Security Number for covered individuals (expect employees listed in Part I of Form 1095-C).
The updated forms also contain a few other changes to the previous versions, including two new “Offer of Coverage” codes indicating conditional offers to spouses on Form 1095-C. The forms also provide clarification about instructions in several areas.
If you’re looking for more resources about reporting under Section 6055 or Section 6056, be sure to check out Q&As on Section 6055 and Q&As on Section 6056 provided by the IRS. And please keep in mind that individual statements for 2016 must be furnished by January 31, 2017, and all IRS returns for 2016 must be filed by February 28, 2017 (or March 31, 2017 if filed electronically).
If you have any questions about these updated forms, don’t hesitate to contact our team at Axiom to schedule a consultation.