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Final ACA Forms 1094 and 1095 Released

Dec 17, 2019 Decorative image

The IRS has released final ACA 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 (ALEs) 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 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 to the IRS is still required on Forms 1094 and 1095. However, as part of the 2019 reporting relief provided by the IRS, some insurers and other providers of minimum essential coverage will not be penalized for failing to send statements to individuals if certain conditions are met. This relief does not extend ALEs as it relates to their full-time employees. ALEs are still responsible for providing an individual statement to each of their full-time employees. For more information, please see our recent blog post, IRS Provides 2019 ACA Reporting Relief.

As required, individual statements must be provided by March 2, 2020. IRS returns must be filed by February 28, 2020, or March 31, 2020, if filed electronically.

Reach out to your Hylant representative for further information.

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