Applicable large employers (ALEs) (those with 50 or more full-time employees, including full-time equivalent employees, in the previous year) are required to file Forms 1094-C and 1095-C to report to the IRS information related to employer shared responsibility provisions. The IRS has released the final forms (Form 1094-C and Form 1095-C) and instructions for employer shared responsibility reporting for 2016.
The final instructions address proposed regulations issued in August 2016, including reporting rules applicable to health reimbursement arrangements (HRAs).
In addition, the IRS has released publications to assist employers with electronic filing. Publication 5164 (Test Package for Electronic Filers of Affordable Care Act (ACA) Information Returns (AIR)) contains general and program specific testing information for use with ACA Assurance Testing System (AATS) in processing year 2017. AATS refers to the process and system used to test software and electronic transmissions prior to accepting forms employers into the AIR System. Publication 5165 (Guide for Electronically Filing Affordable Care Act (ACA) Information Returns for Software Developers and Transmitters) provides procedures for electronic filing of information returns.
Additional guidance regarding health care reform information reporting for the 2016 tax year can be found at Publication 5258 (Affordable Care Act (ACA) Information Returns (AIR) Submission Composition and Reference Guide) and Publication 5223 (General Rules and Specifications for Affordable Care Act Substitute Forms 1095-A, 1094-B, 1095-B, 1094-C, and 1095-C).