Reminders for 2018 Annual Reporting of Health Coverage

The IRS recently released final forms and instructions for the 2018 employer reporting. The good news is that the process and instructions have not changed significantly from last year. However, the IRS has started to assess penalties on the 2015 forms. For that reason, employers should make sure they complete the forms accurately.

The final 2018 forms and instructions can be found at:

• Form 1094 C – https://www.irs.gov/forms-pubs/about-form-1094-c
• Form 1095 C – https://www.irs.gov/forms-pubs/about-form-1095-c
• Form 1094 B – https://www.irs.gov/forms-pubs/about-form-1094-b
• Form 1095 B – https://www.irs.gov/forms-pubs/about-form-1095-b

Employers with self-funded plans can use the B forms to report coverage for anyone their plan covers who is not an employee at any point during the year. The due dates for 2018 are as follows:

• Individual statement (1095 C), due to employees January 31, 2019
• Employer transmittal (1094 C and copies of each 1095 C), due to IRS by February 28, 2019 (paper) OR April 1, 2019 (electronically)

Be sure to file these forms on time. The IRS will assess late filing penalties if you file them after they are due. The instructions explain how to apply for extensions if you think you may miss the deadlines.

The 1095 C form can be sent to employees electronically with the employee’s consent, but that consent must meet specific requirements. The consent criteria include disclosing the necessary hardware and software requirements, the right to request a paper copy, and how to withdraw consent. They are the same consent requirements that apply to the W-2.

Employers must submit the forms electronically if they file 250 or more 1095 Cs. The instructions explain how to request a waiver of the electronic filing requirement.

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