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IRS Continues to Provide Clues About 2017 Forms 1094-C and 1095-C – Not Much has Changed

August 15, 2017

On August 14, 2017 the IRS released its second iteration of the draft Form 1095-C for 2017. Previously on July 27, 2017, the IRS had released drafts of both the Forms 1094-C and 1095-C. We anticipate the instructions to the Forms 1094-C and 1095-C to be released any day. However, as the reporting season is fast approaching, here is a brief summary of what we have learned from the draft Forms released to date.

There are two differences with regards to the draft 2017 Form 1094-C that have been released to date compared to the 2016 Form 1094-C. The first difference is both boxes “B” and “C” on line 22 are now labeled “Reserved”. These boxes will never apply in 2017 as the transition relief for which boxes “B” and “C” could have been checked are no longer applicable. The 2016 Form 1094-C had labeled box “B” on line 22 as “Reserved” but box “C” was still a viable option. This is no longer the case in 2017. The second change is column (e) in Part III of the Form 1094-C is also labeled “Reserved”. Column (e) in Part III of the Form 1094-C was tied to box “C” on line 22 so it is logical that both the box and the column are labeled “Reserved” now that the transition relief provision that related to the box and column can never apply. After reviewing the draft Form 1094-C there are no other obvious differences compared to prior years. However, this could change upon the release of the draft instructions.

There are no obvious changes on the Form 1095-C compared to the 2016 Form 1095-C. Apparently, the IRS released its second iteration of the draft Form 1095-C to emphasize that the “Plan Start Month” box will remain optional on the 2017 Form 1095-C. Having thoroughly reviewed the “Instructions for Recipient” page of the draft Form 1095-C, it appears nothing has changed with regard to lines 14 and 15. The Form 1095-C “Instructions for Recipient” page does not address line 16, so it is not yet possible to know if some of the impossibilities related to line 16 have been corrected by the IRS. We are optimistic, although not holding our breath.

Employers should begin preparing to report on the Forms 1094-C and 1095-C for 2017. It appears little has changed with respect to these Forms compared to previous years. However, we won’t know for certain until the draft instructions are released. We will be sure to provide an update upon the draft instructions being published. Should you have any questions or need assistance with the Forms 1094-C and 1095-C please contact us.

About the author – Ryan Moulder serves as General Counsel at Accord Systems, LLC and is a Partner at Health Care Attorney's P.C. Ryan received his LL.M. from Georgetown University Law Center and his J.D. from Saint Louis University School of Law. He has distinguished himself as a leader in the Affordable Care Act arena and has written and spoken on a variety of ACA topics as it relates to compliance for companies.

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