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|Final ACA Reporting Forms Include Some Changes from Proposed Versions|
Smith, Gambrell & Russell, LLP
Feb. 24, 2015
"The instructions to the final Forms 1094-C and 1095-C include several important clarifications and changes from the draft version of the instructions. For example, the final instructions clarify that an ALEM may use Form 1095-C to report with respect to non-employees enrolled in self-funded coverage (e.g., retirees and COBRA beneficiaries). The draft instructions would have required the ALEM to use Forms 1094-B and 1095-B for non-employee participants. This change allows ALEMs to satisfy all of their reporting obligations using Forms 1094-C and 1095-C."
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