Updated 1095-C Employer Reporting Guide - 2020

The IRS recently provided the final 1095-C employer reporting forms and instructions. The 1095-C forms were modified slightly, primarily to facilitate reporting by employers who offered individual coverage HRAs (ICHRAs) in 2020.

The Form 1094-Cs are pretty much identical to last year.

Minor Changes to  Form 1095-C

• For the first time, employers must report the plan year start month in Part II of the Form 1095-Cs. (This was previously optional)
• Penalties have increased for failing to report, providing incorrect information, or failing to provide copies to full-time employees and covered individuals from $270 a month (maximum of $3,339,000) to $280 a month (maximum of $3,392,000) for 2020 
• Applicable Large Employers (ALEs) who offered ICHRAs will have to provide the employee’s age as of January 1, 2020, use the newly created Codes (1L – 1S) to indicate the type of offer, and provide zip code information on Line 17
• ALEs and employers who offered self-funded group health plan coverage during 2020 must provide 1095s to full-time employees and covered individuals no later than March 2, 2020 (in accordance with the extended deadline) 

Filing Deadlines
Here are the critical filing deadlines for 2020 coverage:

In addition, keep in mind that there are now a handful of states with individual mandates that may require reporting at the state level, and some have deadlines earlier than what is required for federal reporting.
 
All of these items and more are covered in our updated 1095-C & 1094-C Employer Reporting Guide.