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Indicating Transition Relief on 2015 Form 1094-C

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One of the common mistakes resulting in erroneous IRS 2015 ESRP assertions is failure to properly report eligibility for 50-99 or 100+ transition relief on the 2015 Form 1094-C.

I know that box C in line 22 (Section 4980H Transition Relief) needed to be checked along with either code A or B entered in line 23 column (e).

What I'm questioning is whether the Yes or No box (MEC Offer Indicator) was supposed to be checked in line 23 column (a)?

Page 8 of the 2015 instructions could be interpreted either way, what are others doing?



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Interesting question. I have not seen the exact scenario you are describing.  It is certainly frustrating the IRS software did not have better ways to verify the information ALE members inputted on the Form 1094-C.  For example, column (a) on line 23 could have been verified using the Forms 1095-C the ALE member submitted along with the Form 1094-C.  I am not holding my breath for these corrections moving forward and the accuracy of the Forms 1095-C in 2015 were poor so it may not have helped that much.

The instructions on page 8 cross reference the "Section 4980H Transition Relief for 2015" section on page 15.  So long as the ALE member meets the three conditions for the 50-99 transition relief provision (almost all do), I believe the "Yes" box should be checked in column (a) for line 23.

Let me know if you have additional questions - rmoulder@healthcare-attorneys.com.

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Having re-read the instructions many times and now noticing the specific reference to checking the "Yes" box in Part III column (a) with respect to the other transition relief items I've convinced myself that for the 50-99 and 100+ transition relief column (a) should have been checked "No" and the A and B codes in column (e) are what alert the IRS to the relief.

Which makes sense since the other forms of transition relief (such as the 70% offer or non-calendar year relief) don't have an indicator code in column (e) so you have to answer Yes in column (a).




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