IRS Releases Final 2017 Forms 1094-C and 1095-C

On Sept. 28, 2017, the IRS released final forms related to IRC Section 6056 reporting. The instructions are still in draft format. The final forms appear to have no substantial changes from the 2016 forms.

The most notable change is that no Section 4980H transition relief is available beginning with the 2017 reporting year. Thus, all references to such relief have been removed. Specifically, boxes B and C on Line 22 of the Form 1094-C (which were previously used to claim transition relief) have now been marked as “reserved.” Similarly, column (e) of Part III of the Form 1094-C has also been marked “reserved.”

As a reminder, PPACA requires employers (including self-insured, fully insured and uninsured) with 50 or more full-time-equivalent employees to file Forms 1094-C and 1095-C with the IRS and to provide statements to employees to comply with IRC Section 6056 (meant to help the IRS enforce the employer mandate). Specifically, large fully insured employers will need to complete and submit Forms 1094-C and 1095-C (Parts I and II). Large self-insured employers subject to both Sections 6055 and 6056 may combine reporting obligations by using Form 1094-C and completing all sections of Form 1095-C (Parts I, II and III). Small self-insured employers would need to file Forms 1094-B and 1095-B. Employers with grandfathered plans must comply with the reporting requirements as well.

Finally, as a reminder on reporting deadlines for the 2017 calendar year, the deadline to provide information returns to employees or responsible individuals is Jan. 31, 2018. Also, employers filing 250 or more forms must file electronically with the IRS. Employers filing fewer than 250 forms may file by paper or electronically. Paper filings are due by Feb. 28, 2018. Those filing electronically must report by April 2, 2018 (March 31, 2018 falls on a Saturday).

Form 1094-C »
Form 1095-C »
Draft Instructions for Forms 1094-C and 1095-C »