Compliance & Regulatory Update

Employee Benefits

Final Forms for ACA Reporting Released

The Internal Revenue Service (IRS) has released final 2016 forms for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.


  • Forms 1094-B and 1095-B are used by entities reporting under Section 6055, including self-insured plan sponsors that are not Applicable Large Employers (ALEs). Final 2016 versions of these forms and final instructions were released on September 26, 2016.
  • Forms 1094-C and 1095-C are used by ALEs to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans. Final 2016 versions of these forms and final instructions were released on September 30, 2016.


Minor changes were made to the forms, including the addition of two new “Offer of Coverage” codes for use on Form 1095-C. The instructions also included some clarifications.




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