The IRS has released final ACA Reporting Forms 1094-B, 1095-B, 1094-C, and 1095-C for 2017 (to be filed in 2018). Final Instructions have also been released for the C forms.
Background
Applicable large employers, self-insured employers, and health insurance issuers will use the final forms and instructions in 2018 to report on health coverage offered (or not offered) in the 2017 calendar year. The forms have changed very little from the previous year.
Sequoia Clients
If you are a member of our Tech Program you have already received communications from Sequoia regarding your 2017 ACA reporting. If you are a Non-Tech Client, Sequoia recommends you work with a vendor to assist with ACA reporting. Please reach out to your dedicated Customer Service Representative for more information on ACA reporting requirements and recommendations.
For more information on changes made to the forms from last year, see our previous blog post here.
Reporting Deadlines
There has been no indication that the IRS will extend the ACA filing deadlines for 2017. These deadlines tend to come around very quickly in 2018 (IRS Forms 1094/1095 B & C are due by 2/28 (if paper filing) or 3/31 (if e-filing, which is required of employers that file 250 or more information returns) and requisite forms are due to employees by 1/31.
Employers who are subject to ACA reporting should have a strategy and/or a vendor in place and should be prepared to request filing extensions, if necessary.
Links to Final Forms
Final instructions for Forms 1094-C and 1095-C
Final Form 1094-C
Final Form 1095-C
Final Instructions for Forms 1094-B and 1095-B
Final Form 1094-B
Final Form 1095-B
Notice 2017-9 (De Minimus Error Safe Harbor)
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