- Forms 1094-B/1095-B – used by coverage providers to report health plan enrollment required by Code § 6055
- Forms 1094-C/1095-C – used by applicable large employers (ALEs) to report information relevant to Code § 4980H employer shared responsibility penalties required by Code § 6056
ALEs that sponsor self-insured health plans are considered coverage providers and fulfill their Code § 6055 requirement by reporting coverage information on Form 1095-C. The forms also provide information regarding the shared responsibility penalty and premium tax credits.
The new 2017 forms also have a few differences from the 2016 forms:
- Form 1094-B – which is the transmittal for Form 1095-B, is unchanged.
- Form 1094-C – removed line 22 box for “Section 4980H Transition Relief.” This relief was only applicable for the 2015 plan year.
- Forms 1095-B and 1095-C – had no major changes. Although, a new paragraph was added in the instructions for recipients titled “Additional information.” This refers recipients to an IRS webpage that provides an overview of the provisions of the individual shared responsibility, employer shared responsibility, and premium tax credits along with contact information for the IRS Healthcare Hotline for questions.
Per EBIA – Draft instructions should most likely be coming out soon which provide a more complete picture of reporting for the 2017 tax year. There has been no change to the reporting requirements as we’re still under the Affordable Care Act (ACA).