July 13, 2018
On July 11, 2018 the IRS released draft copies of the Forms 1094-C and 1095-C for 2018. We are still awaiting the instructions for both Forms which will provide more details, but we wanted to provide a brief summary of what we learned from the draft Forms.
The only thing that appears to have changed on the Form 1094-C is the year switched from 2017 to 2018. Given our expertise in the ACA field we anticipated this change occurring. That is sarcasm in case you missed it. 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 is a minor change to the draft Form 1095-C in 2018 compared to 2017. On line 1 in part I of the Form 1095-C and column (a) in part III of the Form 1095-C the draft Form 1095-C provides dividers for the entry of the individual’s first name, middle initial, and last name. The 2017 final instructions for the Forms 1094-C and 1095-C already instructed employers to complete line 1 in part I of the Form 1095-C in such a manner. However, the new layout will presumably ensure all Forms 1095-C are completed with an identical name structure. The 2017 final instructions for the Forms 1094-C and 1095-C surprisingly did not provide any name structure guidance for column (a) in part III of the Form 1095-C. As a result, the new name formatting guidance will lead to more uniformity with the Form 1095-C. Perhaps these changes by the IRS are a result of the TIN errors that have plagued almost all employers filing the Forms 1094-C and 1095-C. By having a separate field for an employee’s last name, we are hopeful the IRS will be able to solve the TIN error issues in 2018.
The draft Form 1095-C states the “Plan Start Month” box will remain optional on the 2018 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.
Employers should begin preparing to report on the Forms 1094-C and 1095-C for 2018. 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 Attorneys 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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