The IRS is gearing up for the 2016 ACA filing season. Drafts of the 2016 Forms 1094-C and 1095-C were released on July 7th, and the related draft instructions were released on August 1st.

The 2016 1095-C forms are due to your employees by January 31, 2017. If filing on paper, they must be filed with the IRS by February 28, 2017. If filing electronically, they are due March 31, 2017.
The 2016 draft forms include a significant change to reporting guidelines. Two Box 14 (Series 1) codes have been added: 1J and 1K.  Series 1 codes are used to report information about the type of insurance offer you made to your employee.
The 2016 form defines the new codes as follows:

• Code 1J: Minimum essential coverage providing minimum value offered to you; minimum essential coverage conditionally offered to your spouse; and minimum essential coverage NOT offered to your dependent (s)
• Code 1K: Minimum essential coverage providing minimum value offered to you; minimum essential coverage conditionally offered to your spouse; and minimum essential coverage offered to your dependent(s).

The draft instructions clarify that a conditional offer is an offer that is available to a spouse only if the spouse meets certain conditions, such as not having access to health coverage from another employer.
In 2015, a conditional offer to an employee’s spouse was treated as a regular offer and did not need to be tracked or reported separately.
As we did in 2015, BDB will produce and file 2016 Forms 1095-C on your behalf.  If these new requirements are finalized, additional tracking and reporting will be needed and BDB will provide both the educational and technical support to comply.
If you have any questions, please contact your CSR.
Drafts of the 2016 forms can be found here:

• Draft 2016 Form 1094-C
• Draft 2016 Form 1095-C

Drafts of the 2016 instructions can be found here:

• https://www.irs.gov/pub/irs-dft/i109495c--dft.pdf

At Viventium, we are committed to helping you with the increased compliance requirements that have resulted from rapidly evolving legislation.  We aim to minimize your administrative burden across the entire spectrum of employment-related payroll, tax, HR, and benefits so that you can focus on the work that matters: running your business.  We provide you with this information as a way to amplify your understanding of the impact of regulatory requirements – but please do not construe this information as tax or legal advice.  By nature, this information is subject to revision and might not be the most up-to-date information available.  We encourage you to consult with the appropriate legal and tax advisors before making any decisions.
Topics: ACA, IRS, 1095-C