The Internal Revenue Service (IRS) has released the final version of Forms 1094-C and 1095-C for the 2017 reporting year along with Instructions for Forms 1094-C and 1095-C. As a reminder, these forms are used by employers who must report on their full-time employees under Internal Revenue Code Section 6056. While the forms are substantially similar to the 2016 versions, there are some things worth noting:
- On Form 1094-C, line 22, box C is now designated “reserved” rather than “Section 4980H Transition Relief.” Also, Part III, column (e) is designated “reserved” rather than “Section 4980H Transition Relief Indicator.” This is because certain transition relief that was available under Internal Revenue Code section 4980H for 2016 is not available for 2017.
- On Form 1095-C, the “Plan Start Month” box remains optionalfor 2017.
- Per the instructions, Forms 1095-C that are filed with incorrect dollar amounts on line 15 for the “Employee Required Contribution” may fall under a safe harbor for certain de minimis errors. The safe harbor generally applies if no single amount in error differs from the correct amount by more than $100. If the safe harbor applies, the employer will not have to correct Form 1095-C to avoid penalties. More information on the safe harbor is available in IRS Notice 2017-9.
- For Form 1095-C, line 16, the instructions clarify there is no specific indicator code that an employer should use for a full-time employee waiving coverage.
The deadlines for reporting are just a few months away. Forms 1095-C must be provided to employees by January 31, 2018. If filing electronically with the IRS, Forms 1094-C and 1095-C are due by April 2, 2018 (since March 31st falls on a Saturday). Employers filing less than 250 Forms 1095-C may file paper returns, which are due to the IRS by February 28, 2018.