IRS Releases Final Forms and Instructions for 2020 ACA Reporting

The IRS recently released final instructions for both the 1094-B and 1095-B forms and the 1094-C and 1095-C forms and the final forms for 1094-B, 1095-B, 1094-C, and 1095-C. The forms have generally remained unchanged from prior years. As a reminder, individuals do not pay a penalty for failure to have health coverage. The following summarizes the ACA filing deadlines and responsible parties.

Filing Responsibility

2020 Plan Start Month Box

The 1095-C form retains the “plan start month” box, which was optional for 2015, 2016, 2017, 2018, and 2019. For 2020 reporting, this box is no longer optional and cannot be left blank. This box is intended to provide the IRS with information used to calculate an individual’s eligibility for premium tax credits, which is based on the employer plan’s affordability, calculated by plan year.

Penalties

  • The penalty for failure to file a correct information return is $280 for each return for which the failure occurs, with the total penalty for a calendar year not to exceed $3,392,000.
  • The penalty for failure to provide a correct payee statement is $280 for each statement for which the failure occurs, with the total penalty for a calendar year not to exceed $3,392,000.

Special rules apply that increase the per-statement and total penalties if there is intentional disregard of the requirement to file the returns and furnish the required statements.

10/19/2020