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Time to start thinking about 2016 ACA reporting

By Higginbotham on August 29 , 2016

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Just as you're recovering from the first round of ACA employer reporting, it’s time to start thinking about gathering the data necessary to fill out your 2016 1095-Cs in 2017. To help keep you on your toes, the IRS has already released draft forms and instructions for 2016 reporting under Sections 6055 and 6056.

Luckily, not much appears to be changing.

Only minor changes appear in the draft forms, including the removal of some codes and language related to transitional relief available for 2015 and the addition of two new "Offer of Coverage" codes:

  • Code 1J can be used if: (1) minimum essential coverage providing minimum value was offered to the employee; (2) minimum essential coverage was conditionally offered to the employee’s spouse; and (3) minimum essential coverage was not offered to the employee’s dependent(s).
  • Code 1K can be used if: (1) minimum essential coverage providing minimum value was offered to the employee; (2) minimum essential coverage was conditionally offered to the employee’s spouse; and (3) minimum essential coverage was offered to the employee’s dependent(s).

Additionally, we want to comment on the notices some employers may receive related to employees purchasing coverage through the Marketplace and getting tax credits/subsidies when doing so.

These notices are generally for information purposes only and do not necessarily mean that you will be charged any ACA penalties. They are used to inform applicable large employers subject to the ACA that they may be facing penalties or fines by not providing affordable, minimum-value coverage to that particular employee. The notices also provide contact information for employers who have made the correct offer of coverage to inform the Marketplace that the employee in question is not subsidy-eligible, thereby preemptively defending themselves against any penalties levied by the IRS.

Additional information can be found in these legislative guides:

Draft Forms for 2016 ACA Reporting Released
Employer Appeals of Exchange Subsidy Notices

Tags: Compliance

  
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