The Internal Revenue Service (IRS) recently released final versions of the 2016 Forms 1094-C and 1095-C along with instructions for both forms. These forms will be used by employers who are required to report under Internal Revenue Code Section 6056 on their full-time employees and the employer-sponsored coverage offered.
The 2016 forms include minor revisions and clarifications, including the addition of two new codes for reporting “conditional” offers of coverage to spouses on line 14 of Form 1095-C. One notable clarification is that an employer may not use the affordability safe harbor codes (2F, 2G, 2H) on line 16 of Form 1095-C if the employer fails to offer minimum essential coverage to at least 95% of its full-time employees and their dependents.
The 2016 instructions are noticeably clearer and provide more detailed guidance than last year’s instructions. For example, this year’s instructions discuss how to report on retiree coverage for self-insured plans, which was not clearly addressed previously. In addition, they include several examples to make the guidance more understandable. Employers looking for clarification on various reporting issues, including how to report on COBRA, should find the instructions helpful.