Final Forms for 2020 ACA Reporting

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The Internal Revenue Service (IRS) has released the final forms and instructions for 2020 reporting under Sections 6055 and 6056.

• 2020 Forms 1094-Cand 1095-C (and related instructions) are used by applicable large employers (ALEs) to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.
• 2020 Forms 1094-B and 1095-B(and related instructions) are used by entities providing minimum essential coverage including self-insured plan sponsors that are not ALEs to report under Section 6055.

These updated forms include several clarifications and changes related to 2020 reporting.

• The “Plan Month Start” box is now required for 2020 reporting
• The deadline for furnishing statements to individuals under Section 6055 and 6056 is extended to March 2, 2021
• Penalty relief for reporting incomplete or incorrect information, and providing individual statements under Section 6055 only upon request has been extended

Forms 1095-B and 1095-C were also updated to include changes related to offers of individual coverage health reimbursement arrangements (ICHRAs).

Employers should become familiar with these forms and instructions in preparation to use them for reporting for the 2020 calendar year. Individual statements must be provided by March 2, 2021 and returns must be filed by February 28, 2021 (paper version) or March 31, 2021 (filed electronically).

For more information, download the bulletin or contact your NIS Employee Benefit Consultant.