H&W Draft 2016 1094/1095 Reporting Forms

The IRS has released DRAFT versions of the 2016 1094/1095 reporting forms.  There are very minimal changes to the draft forms over the 2015 versions.  Specifics on the changes follow:

Form 1094-B:     No changes

Form 1095-B:     Although Line 9 was to be left blank on the 2015 version, it was labeled “Small Business Health Options Program (SHOP) Marketplace identifier.”  On the 2016 version, Line 9 has been changed to “Reserved.”

Form 1094-C:     Line 22 option B, on the 2015 version communicated that an ALE was eligible for the “Qualifying Offer Method Transition Relief” which was used to certify that the ALE had made a qualifying offer to at least 95% of its full-time employees.  Since this transitional relief is no longer available, the Line 22 B box has been changed to “Reserved”.

Form 1095-C:     Line 14 which provides the “Offer of Coverage” code has 2 additional options on the 2016 form.  These new codes take into consideration conditional offers of coverage that are made to spouses.  This is to account for health plans that have an eligibility condition attached to their health plan wherein a spouse is only eligible as long as they are not eligible for coverage under another employer’s plan.  The two additional codes that are available on the 2016 form include:

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).

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).

To reiterate, the 2016 forms are DRAFT ONLY and are not to be used for reporting to the IRS.  Instructions for the 2016 forms have NOT been released at this time.  Compliancedashboard provides additional information regarding 1094/1095 reporting.