The IRS has released the final forms and instructions large employers will use to meet their 2018 Employer Mandate reporting obligations under the Patient Protection and Affordable Care Act (ACA).

While the final forms and instructions have not changed significantly this year, employers should take note of the following:

  • Plan Start Month Continues to be Optional: Part II of Form 1095-C provides space to enter a 2-digit number indicating the plan start month. Completion of this field remains optional for 2018.

  • Adjustments to Affordability Threshold: Due to inflation adjustments, the percentage used to calculate employer affordability safe harbors decreased to 9.56% for plan years beginning in 2018, down from 9.69% for plan years beginning in 2017.

  • Separate Fields for First, Middle and Last Names: Rather than a single blank for full names, the forms now include separate fields for each individual’s first name, middle initial, and last name.

  • Electronic Filing Threshold Remains Same: For 2018, the numeric threshold for mandatory electronic filing will continue to be determined on a per-return basis and to apply separately to each type of form. Under this rule, employers issuing 250 or more individual Forms 1095-C are required to file copies of each Form 1095-C, along with Form 1094-C, electronically.

ACA Information Reporting Deadlines Quickly Approaching

ACA information reporting deadlines are quickly approaching, and it can take considerable time and internal resources to gather the information needed to complete the forms. Applicable large employers (those with 50 or more full-time employees, including equivalents, during the prior calendar year) need to prepare now to file on time.

Timely filing means distributing Form 1095 employee statements on or before January 31, 2019 and filing Form 1094-C, together with copies of all Forms 1095-C, by either February 28, 2019 (paper filings) or April 1, 2019 (electronic filings).

Employers should start work as quickly as possible to gather the necessary data.

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