Issue Date: October 2017

The IRS released the 2017 draft forms and instructions for the ACA employer reporting requirement. The 2017 forms and instructions are very similar to those used for 2016. Given that they have only minor changes throughout along with a few clarifications of existing requirements, the most significant change is the deletion throughout of anything referring to §4980H transition relief, which is expired and no longer applicable.

Tips and Reminders

Below are helpful tips and reminders on completing these forms:

  1. Employers planning to use a vendor need to decide now, if they haven’t already. It takes time to understand how to present information to the vendor, in addition to allowing time for preparation, testing, etc. Contact your LISI Regional Sales Manager if you are looking for a vendor.
  2. Box 10 in Form 1095-C asks for the employer’s contact number. It’s important that this number connect to a person who understands the employer’s reporting process or that the person answering the phone knows whom to contact internally.
  3. Statements must be furnished on paper by mail, or hand-delivered, unless there is affirmative consent by the recipient to receive the statement electronically. Information on consent to receive electronic statements can be found here.
  4. Consent to receive statements electronically should address the duration of the consent. If consent forms used last year didn’t specify that consent would be ongoing, new consent may be required for this year.
  5. The Federal Poverty Line Safe Harbor employee contribution for 2017 is a monthly maximum of $95.93.
  6. There is no specific code to enter on Form 1095-C if an employee has waived coverage. When an employee has waived coverage, it is recommended that the employer complete line 16 with a Safe Harbor code, if applicable.
  7. Information reporting penalties may apply for failing to comply (for example, failure to file a correct return is $260 per return). Special rules apply for penalties due to intentional disregard.

To read the complete compliance alert, click here.

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