The IRS has released the 2016 Forms 1094-B, 1094-C and 1095 –A, 1095-B, 1095-C; as well as the finalized instructions for all of the forms. As mentioned previously in an alert in July when the draft forms became available; the Forms 1094-C and 1095-C remain largely unchanged from the 2015 versions. However, there are some notable changes.
The “Plan Start Month” box on Form 1095-C will continue to be optional on the 2016 form. The more significant changes on the Form 1095-C are that codes 1I and 2I are now labelled as “Reserved” and two additional codes have been added:
1J – Minimum essential coverage providing minimum value offered to you; minimum essential coverage conditionally offered to your spouse; and minimum essential coverage NOT offered to your dependent(s)
1K – Minimum essential coverage providing minimum value offered to you; minimum essential coverage conditionally offered to your spouse; and minimum essential coverage offered to your dependent(s)
The Form 1094-C has a minor change on Line 22 Certifications of Eligibility: box “B” is now labelled as “Reserved”, which was previously for the “Qualifying Offer Transition Relief”.
The Instructions for the Forms 1094-C and 1095-C have been amended to include guidance on the new codes and have removed reference to any transitional relief that was applicable to 2015 calendar year plans.
New 2016 Forms 1094-C and 1095-C can be found here: 2016 Form 1094-C, 2016 Form 1095-C and 2016 Instructions for Forms 1094-C and 1095-C. All other forms and instructions can be accessed by searching for the specific document on the IRS Forms and Instructions webpage.
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This information is provided as a courtesy, may change and is not intended as legal or tax guidance. Employers with questions or concerns outside the scope of a Payroll Service Provider are encouraged to seek the advice of a qualified CPA, Tax Attorney or Advisor.