Q: As the year end approaches, has the IRS extended any deadlines for the ACA reporting and are there any changes to the forms this year?


A: The IRS recently released Notice 2020-76 which extends the due date for employers to provide forms to individuals to March 2, 2021. This notice does not extend the due date for filing the forms with the IRS. Currently paper filings are due February 28th and electronic flings are due March 31st.

Draft Form 1095-B now includes a new code for Box 8 which would indicate a small employer is offering an Individual Coverage Health Reimbursement Account (ICHRA). Draft Form 1094-B does not have any changes.

While  Draft Form 1094-C does not indicate any changes, Draft Form 1095-C includes changes to reflect the ability for an employer to offer an ICHRA. The proposed changes to form 1094-C includes the following: 

  • Addition of employees age on January 1, 2020. Since the cost of the lowest-cost silver plan varies by the employee’s age, this section is now included so the IRS can determine whether the ICHRA offered to the employee was considered affordable. At this time, the instructions do not state if this is a required field for employers who do not offer an ICHRA.
  • Eight New codes for Line 14 to indicate the offering of an ICHRA.
  • Addition of Line 17 for an employer offering an ICHRA to report the zip code that was used for determining affordability.

We will let you know once the final forms and full instructions for 2020 have been released.



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