The IRS released draft 2018 forms
for Affordable Care Act (ACA) reporting under Internal Revenue Code
(Code) Sections 6055 and 6056. Draft instructions for 2018 have not yet
been released.
The 2018 draft forms are
substantially similar to the final 2017 versions. However, the revised
version of the Form 1095-C clarifies that the “Plan Start Month” box in
Part II will remain optional for 2018. The IRS previously indicated that
this box may have been mandatory for the 2018 Form 1095-C.
Keep in mind that the 2018
draft instructions for these forms may include additional changes or
clarifications, once released. Also, the IRS may make additional changes
to these forms before releasing final 2018 versions.
What You Need to Do
Employers should become familiar with these forms for reporting for the 2018 calendar year. However, these forms are draft versions only, and should not be filed with the IRS or relied upon for filing.
- 2018 draft Forms 1094-C and 1095-C
were released July 11, 2018, and will be used by applicable large
employers (ALEs) to report under Section 6056, as well as for combined
Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.
- 2018 draft Forms 1094-B and 1095-Bwere
also released in July 2018, and will be used by entities reporting
under Section 6055, including self-insured plan sponsors that are not
ALEs.