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Monday, 12 December 2016 14:27

2016 Changes Reporting to 1095 Forms Due March 2nd, 2017

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As we blogged about last month, the filing deadline for the 1095 reporting required of large employers has been pushed back to March 2nd from January 31st.  There are some general changes to the process, and also changes to the 1095 forms themselves. 


There are a number of general changes to the general ACA Reporting process for 2016:

  • There will again be a “good faith effort” Safe Harbor for employers who file on time; the IRS originally had indicated this Safe Harbor would be for the first year of filing only, for 2015 forms
  • Employers with over 250 Employees MUST file transmittals electronically
  • Employers need to document their attempts to gather accurate SSNs from dependents
  • The IRS has introduced an improved process for TIN matching errors


There are several changes to the 1095-C form itself:

  • There is a new concept on the form recognizing conditional offers – where the employer offers to cover spouse only if they do not have access to other coverage
  • Line 14 Codes (never leave blank) – new codes 1J and 1K are used if a conditional offer is made to spouses
  • Line 14 Code 1I is gone for 2016 – it was only for transitional relief
  • Line 15 – enter self only cost for lowest cost plan, only if line 14 is 1B, 1C, 1D, 1E, 1J, 1K
  • Line 16 – Code 2I is gone for 2016 – was only for transitional relief
  • Keep in mind that Line 16 codes are not required but help you avoid mandate penalties


And, finally, a few clarifications:

  • 1095-C Part III:
    • Do not complete for employees who waive
    • For employees who elected, show employee in addition to all family members
  • 1094-C Transmittals (still due by March 31):
    • Part II, Line 22: Box B will never be checked, Box C is only for non-calendar year plans
    • Part III, ALE Member Info – in column b, EE count will be those working 30 hours +
    • Part IV, Other Applicable Large Employer (ALE) Members – do not list your own ALE
  • 1095-B’s 
    • Generally used by partially self-funded groups under 50 FTEs (ie NOT an ALE)
    • These ONLY need to go to those covered, since non-ALE’s do not need to report an offer
Source: Greatland Corporation
Read 555 times Last modified on Tuesday, 20 December 2016 18:13
Kristen Russell

Kristen founded Fall River Employee Benefits as the culmination of her insurance industry career as an actuary, underwriting executive & consultant. As an Assistant Vice President at Great-West Healthcare (now part of CIGNA), she managed a $1 Billion block of health insurance. She also worked as a Senior Consultant at Reden & Anders, consulting to insurance companies and large employers throughout the country. Ms. Russell received a Bachelor of Science, Business Administration in Actuarial Science, is a member of the American Academy of Actuaries and achieved Fellowship in the Society of Actuaries through a rigorous nine-year series of exams.

Kristen grew up in Iowa but has lived in Colorado since 1993, currently living near our office in the Lower Highlands neighborhood near downtown Denver.  She enjoys bicycling, hiking, traveling and has a special passion for non-profit volunteering. She is married to an incredibly talented photojournalist, has two adult stepdaughters and an adorable Border Collie/Lab mix named Chaco.