On August 6, 2015, the IRS released new draft instructions to accompany the new draft Forms 1094 and 1095, which were released earlier this year. Once final, the 2015 forms will be used for mandatory filings first required in early 2016 to enforce IRC Section 4980H employer penalties. The new draft instructions generally follow the instructions issued in February 2015, but contain some important clarifications and additions. One potential significant change is the reporting requirement for full-time employees covered by collected bargaining agreements under the multiemployer arrangement interim guidance.