News & Press

5 October, 2016

Final 2016 Forms and Instructions for IRS Reporting Requirements: 5 Key Take-Aways

On October 3, 2016, the Internal Revenue Service (IRS) released final 2016 Forms 1094-C and 1095-C and their accompanying instructions. These forms and instructions will be used for Affordable Care Act (ACA) Applicable Large Employer reporting (for compliance with the 'employer mandate') and self-insured large group Minimum Essential Coverage (MEC) reporting for coverage offered in calendar year 2016.

In September 2016, the IRS released final 2016 Forms 1094-B and 1095-B and the applicable instructions for insurance carriers and small employers who self-insure their group health plans to report MEC.

Changes to Form 1094-C are minimal from the 2015 Forms. The most notable changes include:

Changes to Form 1095-C are also minimal from the 2015 Forms, but include these more prominent updates:

The 2016 IRS Forms 1094-B and 1095-B have similar changes for reporting 2016 coverage in 2017. The instructions for both sets of forms include applicable code information to help ensure correct reporting for each line item.

Final Instructions and Forms

Instructions for Forms 1094-C and 1095-C:  

Used by applicable large employers, i.e., those subject to the employer mandate. Self-insured plan sponsors complete the entire Form 1095-C.

Form 1094-C (a transmittal/cover sheet) to the IRS

Form 1095-C to both the IRS and individuals:  

Applicable large employers with insured plans will only complete Parts I and II of Form 1095-C.

Instructions for Forms 1094-B and 1095-B:  

Insurance carriers and small employers with self-insured plans use these forms.

Form 1094-B (a transmittal /cover sheet) to the IRS

Form 1095-B to both the IRS and individuals 


Published October 5, 2016