Similar to last year, there were few changes to be found. The draft forms are typically indicative of what the final version of forms will look like.
Form 1094-C void of changes
Aside from expected date changes, it appears there are no alterations to the draft edition of Form 1094-C when compared to the final 2017 version. This does not mean, of course, that no changes will appear in 1094-C for 2018, but we have to expect any changes issued post draft form will likely be minor.
When we look at the draft copy of Form 1095-C we find minor changes starting at the very beginning. On line 1 in part I — and column (a) in part III — the draft Form 1095-C shows space dividers between the individual’s first name, middle initial and last name.
This marks a change from the 2017 final instructions for the Forms 1094-C and 1095-C, which previously instructed employers to complete line 1, part I of Form 1095-C in this format. The change is likely because of the high number of TIN errors created by the current format.
Additionally, the draft Form 1095-C indicates that the “Plan Start Month” box will remain optional on the 2019 Form 1095-C. We expect the final form and form instructions will cement any changes to how the 2018 forms will be populated.
Preparing for the release of the 2018 forms
The above changes are small adjustments to be sure, and indicate the new versions of these forms will be quite similar to their 2017 counterparts. Nevertheless, instructions for both forms with specific details are still pending. The final forms may be released at any time, but we typically see them within Q4.
We will provide additional information on the changes when these final forms are released. If you have any questions about these forms for 2018 or in their current state, please don’t hesitate to contact us.