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.



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)

IRS Guidance for Employers


The information and materials on this blog are provided for informational purposes only and are not intended to constitute legal or tax advice. Information provided in this blog may not reflect the most current legal developments and may vary by jurisdiction. The content on this blog is for general informational purposes only and does not apply to any particular facts or circumstances. The use of this blog does not in any way establish an attorney-client relationship, nor should any such relationship be implied, and the contents do not constitute legal or tax advice. If you require legal or tax advice, please consult with a licensed attorney or tax professional in your jurisdiction. The contributing authors expressly disclaim all liability to any persons or entities with respect to any action or inaction based on the contents of this blog.

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.