On Monday, the IRS released draft instructions for Forms 1094-C and 1095-C, following the release late last month of new draft 2016 Forms 1094-B and 1095-B and Forms 1094-C and 1095-C.
This year’s draft instructions make minor adjustments to last year’s instructions, including reflecting that the good faith compliance standard applicable to 2015 forms no longer applies for 2016 ACA reporting and that reporting penalties will only be waived by showing reasonable cause.
They also reflect that some transition relief is no longer applicable, including that non-calendar year transition relief (for 2014 plan years) from 2015 does not apply in 2016, and that the Section 4980H Transition Relief, which reduced the 95% threshold to 70% for other ALEs, is only applicable to non-calendar year plans though the end of the plan year ending in 2016.
If filed electronically, forms must be filed by March 31, 2017
Each Employee’s form must be mailed to them by January 31, 2017