IRS Released 2017 ACA Information Returns

November 2017

Notwithstanding executive orders signed by the President and ongoing efforts to repeal and replace the Affordable Care Act (ACA), the reporting requirements still apply for 2017 with the first due date on January 31, 2018. Coverage providers and applicable large employers (ALEs) should continue their efforts to prepare the filings for the 2017 year (due in early 2018).

Providers of healthcare coverage, including employers with self-insured health care plans that are not ALEs must report the individuals (and their spouses and dependents) covered under the plan on Form 1095-B with transmittal Form 1094-B (B Forms), which are used to enforce the individual mandate. ALEs must use Form 1095-C and transmittal Form 1094-C (C Forms) to report information relevant to the employer shared responsibility penalties and the premium tax credits, as well as to report employees (and their spouses and dependents) covered under the employer’s self-insured health care plan.

The IRS released the 2017 B Forms and C Forms, which seem to have little to no changes from the 2016 forms, as summarized below: 
Form   Purpose Change
1094-B Transmittal for Form 1095-B Unchanged
1095-B Health coverage information Unchanged
1094-C Transmittal for Form 1095-C “4980H Transition Relief” removed from Line 22. This expired provision temporarily granted ALEs with fewer than 100 full-time employees and equivalents penalty relief.
1095-C Employer-provided health insurance offer and coverage Unchanged

The first penalty notification will begin late in 2017 based on the 2015 Forms 1094-C, 1095-C and premium tax credit information. ALEs will be notified of their potential liability for an employer shared responsibility payment in Letter 226J. If you receive a Letter 226J, the information should be reconciled to the employer’s records to determine if the amount of the penalty is correct.

Return To Compensation & Benefits Newsletter - Fall 2017