ACA – What Now?

First and foremost, just because we had an election doesn’t mean that everything changes immediately.  The ACA forms are still going to be required for 2016 reporting.  You do have a one month reprieve:  the forms were originally due to employees on January 31, 2017 and now they are  due on March 2, 2017.  That extra time will be helpful to employers, but perhaps even more helpful is the IRS’s change regarding penalty relief.  Originally the IRS said employers would have to show “reasonable cause” to have penalties waived for 2016 reporting.  Instead, they are extending the good faith penalty relief from 2015 reporting for another year.  Saying ” I though this would go away after the election” will probably not be considered a good faith excuse, however so you should be prepared to take the forms seriously again this year.
There are some changes for 2016 reporting. Most notable is the change to the indicator codes denoting spousal coverage.  Codes 1J and 1K have been added to indicate conditional offers of healthcare coverage to spouses.  The codes go on Part II, Line 14 of Form 1095-C.  These codes will cover situations where coverage is available to the spouse only under certain situations such as when the spouse certifies that he or she is not eligible for other group coverage through an employer or not eligible for Medicare.
The deadlines for filing with the feds remain the same.  The deadline for filing employer copies on paper is February 28, 2917.  The deadline for electronic filing is March 31, 2017.  One reason to consider getting it all done in January is that you can get a special discount if you use the Aatrix tax filing service and are ready to send out W-2’s and 1095-C’s at the same time.