On August 2, the Internal Revenue Service (IRS) released revised draft Forms 1094-C and 1095-C, and draft instructions for completing
these forms for the 2016 reporting year (see here). Although these are not final versions,
it is important for employers to review the updates and changes
from the 2015 forms and instructions as they prepare for the 2016
filings.
Background
The Affordable Care Act (ACA) created new reporting requirements
under Sections 6055 and 6056 of the Internal Revenue Code
(Code). The new rules require an applicable large employer (ALE) to
report, on IRS Forms 1094-C and 1095-C, information about offers of
health insurance coverage to full-time employees (FTEs) and the
provision of minimum essential coverage (MEC). The Form 1094-C is
also referred to as the "authoritative transmittal." For
2016, an ALE is generally an employer with 50 or more FTE
equivalents. Under Code Section 6056, an ALE must annually file
with the IRS a report listing the
