Final Forms and Instructions for 2020 ACA Reporting Released

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

• 2020 Form 1094-B and Form 1095-B (and related instructions) will be used by providers of minimum essential coverage (MEC), including self-insured plan sponsors that are not ALEs, to report under Section 6055.
• 2020 Form 1094-C and Form 1095-C (and related instructions) will be 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.

These forms and instructions include a number of changes and clarifications related to 2020 reporting.

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

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

Employers should become familiar with these forms and instructions for reporting for the 2020 calendar year. Individual statements must be furnished by March 2, 2021, and IRS returns must be filed by Feb. 28, 2021 (March 31, 2021, if filed electronically).