IRS Publishes Final 2020 ACA Reporting Forms and Instructions

On Friday, October 16, the IRS published final ACA reporting forms and instructions for the 2020 calendar year.  There were no material changes other than to now require the plan start month (this has been optional in past years) and to newly incorporate information related to offering individual coverage health reimbursement arrangements (ICHRAs) only for employers who adopted an ICHRA (note in Part II of the form 1095-C that the employee’s age on January 1 and employee’s ZIP in line 17 will not be necessary unless reporting an ICHRA).

For applicable large employers (ALEs), here are the final “C” forms and instructions:

For non-ALEs with a self-funded health plan, here are the final “B” forms and instructions:

As a reminder, the IRS extended some relief related to these reports, which you can read about in our previous alert here.  Relatively good news overall here, knowing the reporting is virtually identical to prior years and there are no big surprises.  We have a presentation available to walk our Benefits clients through your reporting so you are confident in auditing the output your chosen technology partner generates for you.  We do encourage you to audit their output as these are your tax forms, which you should keep in your own records for four years.

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information.

This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.