2016 1095-C Draft

1095-C Reporting - Preparing For Year Two

The IRS recently released drafts of Forms 1094-B, 1095-B, 1094-C and 1095-C. The instructions have not yet been released. Although these are only drafts, subject to change, we encourage you to review the proposed changes in order to prepare for 2016 reporting. The changes are as follows:
Form 1095-C | Page 1
The year was updated to "2016" in two places.
"Do not attach to your tax return. Keep for your records." was added below the title of the form.
Part II heading is now “Employee Offer of Coverage” rather than "Employee Offer and Coverage."
IRS indicated that Plan Start Month will be optional again for 2016.
Line 15 text changed as follows:
2015: "Employee Share of Lowest Cost Monthly Premium, for Self-Only Minimum Value Coverage"
2016: "Employee Required Contribution (see instructions)"
Line 16 text changed as follows:
2015: "Applicable Section 4980H Safe Harbor (enter code, if applicable)"
2016: "Section 4980H Safe Harbor and Other Relief (enter code, if applicable)"
Part III text changed as follows:
2015: "If Employer provided self-insured coverage, check the box and enter the information for each covered individual."
2016: "If Employer provided self-insured coverage, check the box and enter the information for each individual enrolled in coverage, including the employee."
The words "or other TIN" were added to the heading for columns b and c in Part III.
Form 1095-C | Page 2 Instructions for Recipient
The year was updated to "2016."
Line 2 instructions changed "issuer" to "employer."
Part II heading is now "Employee Offer of Coverage" rather than "Employee Offer and Coverage."
For code 1A, the bolded text was added: "Minimum essential coverage providing minimum value offered to you with an employee required contribution for self-only coverage equal to or less than 9.5% (as adjusted) of the 48 contiguous states single federal poverty line and minimum essential coverage offered to your spouse and dependent(s) (referred to here as a Qualifying Offer). This code may be used to report for specific months for which a Qualifying Offer was made, even if you did not receive a Qualifying Offer for all 12 months of the calendar year. For information on the adjustment of the 9.5%, see IRS.gov."
Code 1I is now marked as "Reserved."
Codes 1J and 1K have been added:
IJ-"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)."
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)."
Line 15 instructions changed as follows:
2015: This line reports the employee share of the lowest-cost monthly premium for self-only minimum essential coverage providing minimum value that your employer offered you. The amount reported on line 15 may not be the amount you paid for coverage if, for example, you chose to enroll in more expensive coverage such as family coverage. Line 15 will show an amount only if code 1B, 1C, 1D, or 1E is entered on line 14. If you were offered coverage but not required to contribute any amount towards the premium, this line will report a "0.00" for the amount.
2016: This line reports the employee required contribution which is the monthly cost to you for the lowest-cost self-only minimum essential coverage providing minimum value that your employer offered you. The amount reported on line 15 may not be the amount you paid for coverage if, for example, you chose to enroll in more expensive coverage such as family coverage. Line 15 will show an amount only if code 1B, 1C, 1D, 1E, 1J, or 1K is entered on line 14. If you were offered coverage but there is no cost to you for the coverage, this line will report a "0.00" for the amount. For more information, including on how your eligibility for other healthcare arrangements might affect the amount reported on line 15, see IRS.gov.
Form 1095-C | Page 3 Continuation Page
The year was updated to “2016” in two places.
The words "or other TIN" were added to the heading for columns b and c.
Form 1094-C | Page 1
The year was updated to "2016" in two places.
Box B on Line 22 is now marked "Reserved."
Form 1094-C | Page 2
The year was updated to "2016" in two places.
The words "Section 4980H" were added to the beginning of the Column b heading.
Form 1094-C | Page 3
The year was updated to "2016" in two places.
1095-B Changes ►