IRS Releases Final 2020 Forms 1094/1095 and Instructions

The IRS recently issued the final versions of the 2020 Forms 1094-B, 1095-B, 1094-C, and 1095-C, including the related instructions (B Form Instructions and C From Instructions) that employers, plan sponsors, and insurers must use to comply with reporting requirements under the Affordable Care Act (ACA). It is important to note, the forms are mostly unchanged from 2019, except for some additional information regarding Individual Coverage Health Reimbursement Arrangements (ICHRAs).

Changes to the 1095-C

Individual Coverage HRAs (ICHRAs) – For plan years beginning on or after January 1, 2020, employers may offer HRAs integrated with individual health insurance coverage or Medicare, subject to certain conditions (ICHRAs). The new 1095-C now includes new codes for reporting offers of ICHRAs and new lines for reporting required information.

Plan Start Month – The plan start month, which in years past was an optional field to complete, is now required on the 2020 form. Applicable Large Employers (ALEs) must enter a two-digit number.

Changes to the 1095-B

New Coverage Code – As mentioned above, employers are now allowed to offer ICHRAs subject to certain conditions. Form 1094-C was modified to include an additional code for coverage under an ICHRA.

It is always important to read the instructions to complete the forms thoroughly, as there can be some nuances based on the coverage offered. Have questions regarding ACA reporting? Employers Council is here to help.