2017 ACA Form Updates & Deadlines

As of today and into the foreseeable future, the dreaded ACA reporting is still required for applicable large employers (ALE) and self-insured plan sponsors that may not be an ALE. It is important to remember that the 2017 individual statements must be furnished by January 31, 2018. The 2017 IRS filing deadline is February 28, 2018 (April 2nd if filing electronically).

On Sept. 28, 2017, the Internal Revenue Service (IRS) released final 2017 forms for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.

  • 2017 Forms 1094-C and 1095-C (and related instructions) are used by applicable large employers (ALEs) to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.
  • 2017 Forms 1094-B and 1095-B (and related instructions) are used by entities reporting under Section 6055, including self-insured plan sponsors that are not ALEs.

Final instructions for 2017 were released in early October. The 2017 forms are substantially similar to the 2016 versions but there are changes to be aware of:

  • Section 4980H Transition Relief. Several forms of transition relief were available to some employers under Section 4980H for the 2015 plan year (including any portion of the 2015 plan year that fell in 2016). However, no Section 4980H transition relief is available for 2017. As a result, the 2017 instructions for Forms 1094-C and 1095-C were revised to remove references to Section 4980H transition relief. In addition, Form 1094-C has been revised to remove references to this transition relief. Specifically, the following two sections on Form 1094-C related to this transition relief have been designated as “Reserved” and should not be used: Part II, in the “Certifications of Eligibility” Section on Line 22, Box C; and Part III, in the “ALE Member Information – Monthly” table, column (e).
  • Updated Penalty Amounts. Both sets of 2017 instructions include updated penalty amounts for failures to file returns and furnish statements in 2017. The adjusted penalty amount is $260 per violation, with an annual maximum of $3,218,500 (up from a maximum of $3,193,000, for 2016).
  • Formatting Returns Filed with the IRS. Both sets of 2017 instructions clarify that all returns filed with the IRS must be printed in landscape format.
  • Code Series 2 (Section 4980H Safe Harbor Codes and Other Relief). The 2017 instructions for Forms 1094-C and 1095-C clarify that there is no specific code to enter on line 16 to indicate that a full-time employee who was offered coverage either did not enroll or waived the coverage.

 Please download our compliance bulletin for a detailed listing of changes and extensive overview.