New Updates for Non-Calendar Year Plans

Our latest 2016 update includes some interface changes to account for the new guidelines for ALE members that offer a non-calendar year health plan.

In short, many ALEs will no longer be able to select 4980h Transition Relief on their 1094-C unless they participated in a non-calendar year plan. To qualify, they needed to have offered coverage where the plan began in 2015 and ended in 2016.  

The IRS defines non-calendar year plans as:

” For the 2016 calendar year, the transition relief described below is applicable only if an ALE Member (or any other member of the ALE Member’s Aggregated ALE Group, if applicable) offers coverage under a health plan with a plan year beginning on a date other than January 1 (a non-calendar year plan year), and only for calendar months in 2016 that fall within that 2015 plan year.”

From IRS Instructions for Forms 1094-C and 1095-C (2016)

The following are now only available for ALEs with a non-calendar year plan:

  • Section 4980h transition relief (Form 1094-C, Line 22 Box C) :
    • (50-99 transition relief)
    • (100 or more transition relief)
  • Employers offered health coverage to at least 70% of full-time employees (and their dependents) in 2015. If the ALE member offered coverage under more than one health plan with different years, the relief applies through the last day of the latest of the plan years. (Form 1094-C, Lines 23–35, Column (a))
  • Under certain circumstances where dependent health care coverage was not previously offered, but steps are being taken to extend dependent coverage.  (Form 1094-C, Lines 23–35, Column (a))

BoomTax provides built-in guidance to help you accurately complete your 1094-C. We will check to make sure you offer a non-calendar year before showing these additional types of relief. This allows us to streamline your data entry and make sure that your forms are correctly entered.


BoomTax, The Boom Post, and its affiliates do not provide tax, legal or accounting advice. This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors prior to engaging in any transaction.

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