IRS Releases Final 2017 Forms 1094 and 1095

Final Form Instructions Not Yet Released

The IRS has released the final Forms 1094-B, 1095-B, 1094-C, and 1095-C for calendar year 2017 reporting. Employers are required to report in early 2018 for calendar year 2017.

• Form 1094-B (transmittal)
• Form 1095-B
• Form 1094-C (transmittal)
• Form 1095-C

The most significant change to the 2017 forms is the removal of the “Section 4980H Transition Relief” box from line 22 of Form 1094-C. This transition relief is no longer available to employers. In addition, while the final 2017 instructions for these forms have not yet been released, draft instructions for both the B Series and the C Series forms are available from the IRS.

Who is Required to Report?
Forms 1094-B and 1095-B are used by insurers, self-insuring employers, and other parties that provide minimum essential health coverage (regardless of size, except for large self-insuring employers) to report information on this coverage to the IRS and to covered individuals. Applicable large employers (generally those with 50 or more full-time employees, including full-time equivalents or FTEs) will use Forms 1094-C and 1095-C to report information to the IRS and to their full-time employees about their compliance with the employer shared responsibility provisions (“pay or play”) and the health care coverage they have offered. Employers subject to both reporting provisions (generally self-insured employers with 50 or more full-time employees, including FTEs) will satisfy their reporting obligations using Forms 1094-C and 1095-C.

Information Reporting Deadlines 
Under current law, a copy of Form 1095-B must be furnished to the person identified as the “responsible individual” on the form (may be the primary insured or a related person, such as a parent or spouse who submitted the application for coverage) by January 31, 2018. Forms 1094-B and 1095-B are also required to be filed with the IRS by February 28, 2018 (or April 2, 2018, if filing electronically).