IRS issues draft ACA Forms 1094-C, 1095-B, and 1095-C

The IRS has posted on its website three draft 2015 forms for use by employers under the Patient Protection and Affordable Care Act (PPACA) (P.L. 111-148): (1) Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns; (2) Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, to be provided to employees and the IRS; and (3) Form 1095-B, Health Coverage, to be used by employers report certain information to the IRS and to taxpayers about individuals who are covered by minimum essential coverage and therefore are not liable for the individual shared responsibility payment. The forms are reproduced in this Report Letter on pages 9–12.

Form 1095-C

Note about 2015 Form 1095-C:

• The draft is generally unchanged from the 2014 Form 1095-C, except for the addition of one new field, titled “Plan Start Month.” This new field is optional for 2015. This means filers can choose to add this field and provide plan year information, to add this field and enter “00” or, at their option, to leave this new field out (thus using the 2014 format). For 2016 and beyond, this field will be required.

• The draft also includes a continuation sheet that filers use if they need to report coverage for more than six individuals.

• For 2015, the indicator codes in Part II, line 14, “Offer of Coverage” will remain unchanged from those in 2014. See the 2014 instructions for Forms 1094-C and Forms 1095-C for more information on the 2014 codes.

• For 2016 and beyond, filers will need to include two additional codes, if applicable.

These new indicator codes will indicate to the IRS and to full-time employees that the employer’s offer to the spouse is a conditional offer. For more information see the FAQs on www.irs.gov. (http://apps.irs.gov/app/picklist/list/draftTaxForms.html, June 2015.)

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