The Internal Revenue Service (IRS) recently released the 1094-C/1095-C forms and instructions to be used by Applicable Large Employers (ALEs) for the 2018 tax year reporting required by the Affordable Care Act (ACA). ALEs sponsoring a self-funded health plan may use Part III of Form 1095-C to provide individual coverage information to plan participants in lieu of providing Form 1094-B, the form typically used by insurance carriers to report coverage provided by a fully insured plan.
For the most part, the 2018 forms and instructions are the same as last year’s but please note the following minor updates:
- Form 1095-C Part I – The employee name field is now three separate fields (first, middle initial, last). If the employee does not have a middle initial, that field may be left blank.
- Form 1095-C Part II – The Plan Start Month box in Part II will continue to be optional.
- Form 1095-C Part III – The employee name field is now three separate fields (first, middle initial, last). If the employee does not have a middle initial, that field may be left blank.
- 2018 Form 1094-C/1095-C Instructions – Penalties for reporting failures and errors will increase to $270 per violation up to an annual maximum of $3,275,500. Please note: Penalty limits apply separately to IRS information returns and individual statements.
- Form 1095-C must be sent out to employees by January 31, 2019.
- Paper filings of Forms 1094-C and 1095-C must be printed in landscape format, sent by First Class Mail, and postmarked no later than February 28, 2019.
- Electronic filing of the 1094-C and 1095-C must be submitted to the IRS by April 1, 2019.
Reminder: Electronic filing is required when filing 250 or more of a particular form type. Electronic returns must be submitted to the IRS using the ACA Information Return System (AIR). For the operational status of the AIR system, please click here.
If you have questions or would like additional information about ACA reporting, please feel free to contact us at [email protected].