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Last night, the IRS released DRAFTS of the forms and instructions that employers will use for 2019 reporting under the Affordable Care Act (ACA). It is expected the IRS will finalize the materials in the next month. In the meantime, the drafts can help employers and their vendors begin to prepare for the upcoming reporting cycle.

For applicable large employers (ALEs):

For employers that self-fund a minimum essential coverage plan:

Background

Applicable large employers (ALEs), which generally are entities that employed 50 or more full-time and full-time-equivalent employees in the prior year, are required to report information about the health coverage they offer or do not offer to certain employees. To meet this reporting requirement, the ALE furnishes Form 1095-C to the employee or former employee and files copies, along with transmittal Form 1094-C, with the IRS.

Employers, regardless of size, that sponsor a self-funded (self-insured) health plan providing minimum essential coverage are required to report coverage information about enrollees. To meet this reporting requirement, the employer furnishes Form 1095-B to the primary enrollee and files copies, along with transmittal Form 1094-B, with the IRS. Self-funded employers that also are ALEs may use Forms 1095-C and 1094-C in lieu of Forms 1095-B and 1094-B.

Information is reported on a calendar-year basis regardless of the employer’s health plan year or fiscal year.

2019 Forms and Instructions

The IRS typically releases ACA reporting materials in late summer or early fall, but this year it is already mid-November and we are just now seeing the 2019 materials in draft form.

The delay had caused widespread speculation that the IRS would be making substantial changes in the forms and instructions for 2019. Fortunately, that appears not to be the case. The 2019 draft forms and instructions generally are the same as the prior year’s materials. The formats, line numbers, and indicator codes have not changed, so employers and their advisors should have little trouble working with the new materials for 2019.

Due Dates

The due date to furnish 2019 forms to individuals is January 31, 2020, while the due date to file copies with the IRS, including the appropriate transmittal form, will depend on whether the employer files electronically or by paper. Entities that provide 250 or more forms to individuals are required to file electronically with the IRS.

The due dates for 2019 reporting are:

  • January 31, 2020: Deadline to furnish 2019 Form 1095-C (or 1095-B, if applicable) to employees and individuals
  • February 28, 2020: Deadline for paper filing of all 2019 Forms 1095-C and 1095-B, along with transmittal form 1094-C or 1094-B, with the IRS
  • March 31, 2020: Deadline for electronic filing of all 2019 Forms 1095-C and 1095-B, along with transmittal form 1094-C or 1094-B, with the IRS

Summary

Employers are encouraged to work with experienced vendors, tax advisors, and payroll administrators to review how the ACA reporting requirements apply to their situation.

ThinkHR is continuing to monitor developments and we will post the final 2019 forms and instructions on this blog as soon as they are released by the IRS.

Kathy Berger
Kathy Berger is ThinkHR’s principal benefits consultant. She is a Certified Employee Benefits Specialist (CEBS) with over 25 years of experience working with brokers and employers. Kathy uses her extensive knowledge of ERISA, HIPAA, the ACA, and other benefits laws and regulations to assist our clients with practical information in clear language.