Draft IRS Forms 1094 & 1095 Released

Today, The IRS released draft Forms 1094 & 1095 along with related instructions for the 2018 tax year.

“Wait…what are these forms, who files them and who gets them?”

Great questions!  Here’s a recap:

• First, there are “B” and “C” versions of the forms.
  • “B” forms are to be filed by minimum essential coverage providers (think insurers, government-sponsored programs and some self-insuring employers per IRS Code §6055).
  • “C” forms are to be filed by applicable large employers (ALE’s) to comply with IRS Code §6056 (providing the IRS data so they may administer employer shared responsibility as well as receipt of premium tax credits).
    • ALEs with self-insured health plans must also report coverage on Form 1095-C.
• Second, Form 1095-B and Form 1095-C are provided to individuals as well as the IRS.
• Last, there are changes in the 2018 forms—but minimal:
  • Form 1095-C and a similar change in Part IV of Form 1095-B includes a separate field for each covered individual’s data; and
  • Penalty amounts increased for reporting failures.