It seems like just yesterday we were all having such fun with the 2015 Form 1095-C, doesn’t it?
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But believe it or not, 2016 reporting is just around the corner, and the IRS has released draft instructions for the 2016 Forms 1094-C and 1095-C.
Here are some of the key changes from last year:
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Qualifying Offer Method Transition Relief is not available for 2016.
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Language reminding recipients to keep their Forms 1095-C rather than submit them with their tax returns has been added.
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Form 1095-C codes 1I (line 14) and 2I (line 16) are no longer applicable, as they were used for transition relief that was available for 2015 only. So these codes have been reserved, meaning they will not be used for 2016 reporting.
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New 1095-C codes have been added for line 14: 1J and 1K. These relate to conditional offers of spousal coverage—for example, an offer to cover an employee’s spouse only if the spouse is not eligible for coverage under Medicare or a group health plan sponsored by another employer.
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Only limited forms of transition relief remain for 2016, as opposed to the numerous transition relief options that were available in 2015
We’ll keep you posted on when the final versions of these filing instructions are available, as well as other updates you need to know about Forms 1094-C and 1095-C. Stay tuned!
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 Jennifer Carsen, JD,is a Senior Legal Editor for BLR’s human resources and employment law publications, focusing on benefits compliance. In the past, she served as the managing editor of California Employer Resources (CER), BLR’s California-specific division, overseeing the content of CER’s print and online publications and coordinating live events and webinars for both BLR and CER.
Before joining CER in 2005, Ms. Carsen was a Legal Editor at CCH, Inc. and practiced in the Labor & Employment Department at Sidley & Austin, LLP in Chicago. She received her law degree from the New York University School of Law and her B.A. from Williams College. She is a member of the New Hampshire Bar Association.
Questions? Comments? Contact Jen at jcarsen@blr.com for more information on this topic
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