There are a number of general changes to the general ACA Reporting process for 2016:

• There will again be a “good faith effort” Safe Harbor for employers who file on time; the IRS originally had indicated this Safe Harbor would be for the first year of filing only, for 2015 forms
• Employers with over 250 Employees MUST file transmittals electronically
• Employers need to document their attempts to gather accurate SSNs from dependents
• The IRS has introduced an improved process for TIN matching errors

There are several changes to the 1095-C form itself:

• There is a new concept on the form recognizing conditional offers – where the employer offers to cover spouse only if they do not have access to other coverage
• Line 14 Codes (never leave blank) – new codes 1J and 1K are used if a conditional offer is made to spouses
• Line 14 Code 1I is gone for 2016 – it was only for transitional relief
• Line 15 – enter self only cost for lowest cost plan, only if line 14 is 1B, 1C, 1D, 1E, 1J, 1K
• Line 16 – Code 2I is gone for 2016 – was only for transitional relief
• Keep in mind that Line 16 codes are not required but help you avoid mandate penalties

And, finally, a few clarifications:

• 1095-C Part III:
  • Do not complete for employees who waive
  • For employees who elected, show employee in addition to all family members
• 1094-C Transmittals (still due by March 31):
  • Part II, Line 22: Box B will never be checked, Box C is only for non-calendar year plans
  • Part III, ALE Member Info – in column b, EE count will be those working 30 hours +
  • Part IV, Other Applicable Large Employer (ALE) Members – do not list your own ALE
• 1095-B’s 
  • Generally used by partially self-funded groups under 50 FTEs (ie NOT an ALE)
  • These ONLY need to go to those covered, since non-ALE’s do not need to report an offer