The IRS has released draft ACA Reporting Forms 1094-B, 1095-B, 1094-C, and 1095-C for 2017 (to be filed in 2018).  Draft Form Instructions have also been released.



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.



  • Form 1094-B is unchanged.
  • Form 1094-C: Mention of section 4980H transition relief has been removed, due to the Transitional Reinsurance Fee ending in 2016.
  • 1095-C: A note in the instructions has been added to line 16, stating that “There is no specific code to enter on line 16 to indicate that a full-time employee offered coverage either did not enroll in the coverage or waived the coverage.” In addition, a new note was added about whether a corrected return needs to be filed due to an error on line 15.  More specifically, the draft instructions reference Notice 2017-9, which discusses de minimus errors that will not result in a penalty.
  • Forms 1095-B and 1095-C have been amended to include a new paragraph entitled, “Additional Information” that refers recipients to a helpful IRS website. The additional information also includes contact information for an IRS Healthcare Hotline.


Note: These forms and instructions have been released as drafts only and should not be relied upon.  Employers should wait to review the finalized forms.



Draft instructions for Forms 1094-C and 1095-C

Draft Form 1094-C

Draft Form 1095-C

Notice 2017-9 (De Minimus Error Safe Harbor)



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Joanna Castillo– Joanna is the Client Compliance Manager for Sequoia, where she works with our clients to optimize and streamline benefits compliance. In her free time, Joanna enjoys live music, college football, travel, and walking her dog in Golden Gate Park.