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New ACA Draft Forms 1094 and 1095 Released

Nov 21, 2019 blog featured image

The IRS has released draft Forms 1094 and 1095, and related instructions, for the 2019 tax year. These forms are to be filed in early 2020 by applicable large employers and providers of minimum essential coverage, including self-funded plan sponsors.

Form 1094-C and Form 1095-C (and related instructions) are to be used by applicable large employers (ALEs) to report whether an offer of health coverage was made to each full-time employee and if so, information about the offer of coverage. ALEs that sponsor self-funded health plans will include information on which employees and dependents were covered during each month of the year.

Form 1094-B and Form 1095-B (and related instructions) are to be used by entities that are not applicable large employers, yet are providers of minimum essential coverage. This includes insurance carriers and self-funded employers that are not ALEs.

The 2019 forms and instructions are almost identical to the 2018 versions. The filing year of the forms and corresponding due dates have been updated, as well as the maximum penalty amount for failing to file correct forms and the percentage to be used to determine affordability. The “Plan Start Month” box in Part II of Form 1095-C will remain optional for 2019. Finally, the reference to the individual mandate penalty has been removed.

Despite the individual mandate penalty being reduced to $0 beginning in 2019, full reporting is still required on Forms 1094 and 1095. Individual statements must be provided by January 31, 2020. IRS returns must be filed by February 28, 2020, or March 31, 2020, if filed electronically.

While it seems unlikely, the IRS may make additional changes to these forms before releasing final 2019 versions.

Please contact your Hylant representative with any questions you have.

The above information does not constitute advice. Always contact your employee benefits broker or trusted adviser for insurance-related questions.

Author Holly Wahl, Hylant Vice President, Employee Benefits Compliance Leader

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