IRS Releases Updated ACA Reporting Forms

Written by benefitexpress | October 6, 2017

2017 ACA Reporting Forms

The IRS has released their updated forms for the 2017 plan year, along with updated instructions. This is what you need to know.

There are no major changes to forms 1094-B 1094-C and 1095-B 1095-C. The instructions for the B series and C series forms do make several clarifications and tweaks:

  1. The de minimis safe harbor rule - Under the IRS de minimis safe harbor, there's no need to correct an error (or inform participants) if it is under $100. This year's instructions clarify this rule also applies to errors on line 15 of 1095-C.
  2. Reporting COBRA Coverage - The new instructions include a link to the IRS "Questions and Answers" (FAQ) on reporting COBRA coverage for former employees. Reminder: The IRS has stated their FAQs do not have the weight of law unless stated otherwise.
  3. Safe Harbor Coding - Employers indicate if they qualify for safe harbor/relief from certain penalties on Line 16. This year's instructions state there is no specific Line 16 code for employees who waive/do not enroll in coverage.
  4. Start Month - In 2016, furnishing information on the plan start month was optional. It is still optional in 2017, but the IRS has noted it may be mandatory in 2018.


Topics: Legislative Update, Affordable Care Act