ACA 2019 YEAR END CHANGES#

Government Websites
2018 Instructions for Forms 1094C ad 1095C:
https://www.irs.gov/pub/irs-pdf/i109495c.pdf

2018 1095C Form:
https://www.irs.gov/pub/irs-pdf/f1095c.pdf

2018 1094C Form:
https://www.irs.gov/pub/irs-pdf/f1094c.pdf

Affordable Care Act Information Returns (AIR) Program:
https://www.irs.gov/e-file-providers/air/affordable-care-act-information-return-air-program

Questions and Answers about Information Reporting on Form 1094-C and Form 1095-C:
https://www.irs.gov/affordable-care-act/employers/questions-and-answers-about-information-reporting-by-employers-on-form-1094-c-and-form-1095-c

Affordable Care Act Information Returns Schemas and Business Rules:
https://www.irs.gov/e-file-providers/air/affordable-care-act-information-returns-schemas

What's New

• Year changed on the Form 1095-C and Form 1094-C
  
• 1095C and 1094C will no longer include employees who were not full-time employees in any month of the year and were not enrolled in an ACA benefit plan.
  
  

Due Dates
Forms 1095-C for the 2018 calendar year must be furnished by January 31, 2019.
Forms 1094-C and 1095-C are required to be filed by February 28, 2019, or April 1, 2019, if filing electronically.

Affordability Percentage Threshold
References to 9.5% in the section 4980H affordability safe harbors and Qualifying Offer Method are applied based on the percentage as indexed for purposes of applying the affordability thresholds under section 36B (the premium tax credit). The percentage, as adjusted, is 9.69% for plan years beginning in 2017, and 9.56% for plan years beginning in 2018.

Note: 9.86% for plan years beginning 2019

End of “Good Faith Effort”
The IRS has not extended “good faith transition relief” for the 2018 reporting year and is not expected to do so. In previous reporting years, the IRS did not penalize employers for incorrect or incomplete 1095-C and 1094-C forms, as long as they were able to prove that a “good faith” effort was made to comply with the ACA requirements.