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