Q: We're currently gathering information for the employer reporting forms. Are there any changes to the forms for this year?
A: There are two major changes to the form this year.
First, there will be no delay in the delivery dates for the forms—you must give them to your employees by January 31st. These forms must make it to the IRS by February 28th (if by paper) or March 31st (if filing electronically).
The other major change this year, is that a "good faith effort" to file does not relieve you as the employer from penalties for mistakes. That means that you have to start gathering information as soon as possible.
The IRS has released the 2016 forms for the 1095-C and the 1094-C, with instructions for both found here.
There are minor changes to this year's forms; their completion will be similar to last year.
On the 1095-C form, you must enter the plan start month this year. On line 14, the 1 codes and the 1I codes (signifying a qualifying offer for transition relief) have been removed, as they no longer apply.
Two new codes have been added for employers who only offer health insurance to a spouse if they are not eligible for coverage under Medicare or other employer’s group health plan.
This new code is either 1J (if conditional coverage is offered to spouse but not dependents), or 1K (if conditional coverage is offered to spouse and dependents).
The Line 15 description has changed to "Employee Required Contribution" to clarify what goes on this line. The 2I code was deleted from line 16, as (again) the transitional relief is no longer available.
As for changes on the 1094-C form, Box B has been removed from Line 22 box B, since qualifying offer transition relief is not available.
The final documents were released September 30th, allowing you to start your forms. Last year was the "practice year"—this year is the real deal! The IRS is using the data from these forms to assist with accessing the employer penalty.
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