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Forms 1094 and 1095 Available Now for 2019

01.16.2020

The IRS recently released final Forms 1094/1095-B (B Forms) and Forms 1094/1095-C (C Forms), and related instructions, for the 2019 tax year. As you may recall, the B Forms are filed by minimum essential coverage providers (mostly insurers and government-sponsored programs, but also some self-insuring employers) to report coverage information in accordance with Internal Revenue Code Section 6055.

The C Forms are filed by applicable large employers (ALEs) to comply with Sec. 6056, providing information that the IRS needs to administer employer shared responsibility under Sec. 4980H and eligibility for premium tax credits. In addition to being filed with the IRS, Forms 1095-B and 1095-C are furnished to individuals. ALEs with self-insured health plans report coverage information on Form 1095-C.

Revisions of note

No material changes have been made to the forms, either from previous years or from the drafts released in November. However, there are some minor revisions of note. For example, the “Instructions for Recipient” included with Form 1095-B and 1095-C have been revised to reflect the reduction of the individual shared responsibility penalty to zero.

Also, the final instructions for both the B Forms and the C Forms have added a “What’s New” section summarizing the relief announced in IRS Notice 2019-63 and include other modifications related to that relief. As a reminder, Notice 2019-63:

  • Extends, to March 2, 2020, the deadline for furnishing Form 1095-B and Form 1095-C to individual recipients,
  • Continues good faith penalty relief for certain reporting failures, and
  • Provides relief from penalties for reporting entities that don’t automatically furnish Form 1095-B or Form 1095-C to certain individuals, so long as specified conditions are met.

Separately, as of this writing, the Affordable Care Act Information Returns (AIR) Operational Status webpage indicates that electronic filing will begin on Wednesday, January 15, 2020.

Better late than …

The 2019 forms and instructions were finalized much later than in previous years. Although the reason for the delay is unclear, it may be related to relief from the requirement to automatically furnish Forms 1095-B and 1095-C to certain individuals, which stems from the effective elimination of the individual shared responsibility.

Entities responsible for furnishing Forms 1095-B and 1095-C to individuals should review Notice 2019-63 carefully to determine whether they qualify for the relief, which is especially limited for applicable large employers reporting enrollment in their self-insured health plans.

Also, some states have enacted, or are considering, individual coverage mandates with a corresponding requirement to furnish enrollment information to employees and other covered individuals. Employers and other coverage providers in those states should familiarize themselves with state reporting rules.

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