After much delay, the IRS has finally released the final Forms 1094-B, 1095-B, 1094-C, and 1095-C for calendar year 2019 reporting. Employers are required to report in early 2020 for calendar year 2019. You can find the forms for calendar year 2019 reporting here:
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1094/1095-B |
1094/1095-C |
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1094/1095-B Instructions |
1094/1095-C Instructions |
What Changed?
For calendar year 2019, the 6055 and 6056 reporting process is largely unchanged. Notably, the instructions for both sets of forms no longer include statements related to the individual shared responsibility penalty, which was reduced to $0 in 2019. While there is no penalty to individuals, the employer shard responsibility penalty still applies. Additionally, the information reported in these forms is valuable for determining whether an individual is eligible for a premium tax credit. See IRS Publication for details.
For purposes of determining affordability of employer-sponsored coverage when using the Qualified Offer method, the instructions note inflation adjustments to the 9.5% threshold. This percentage is 9.86% for plan years beginning in 2019, which is an increase from 9.56% in 2018.
Who Is Required to Report?
1094-B and 1095-B: These forms are used by insurers, self-insuring employers, and other parties that provide minimum essential health coverage (regardless of size, except for large self-insuring employers) to report information on this coverage to the IRS and to covered individuals. Note: Self-insuring employers with less than 50 full-time or full-time equivalent employees will use these forms to report information on coverage to the IRS and to covered individuals. Self-insuring employers with 50 or more full-time or full-time equivalent employees will use the C forms—see below.
1094-C and 1095-C: Applicable large employers (generally those with 50 or more full-time employees, including full-time equivalents or FTEs) will use Forms 1094-C and 1095-C to report information to the IRS and to their employees about their compliance with the employer-shared responsibility provisions (“pay or play”) and the health care coverage they have offered. Employers subject to both reporting provisions (generally self-insured employers with 50 or more full-time employees, including FTEs) will satisfy their reporting obligations using the C Forms.
Information Reporting Deadlines
The upcoming deadlines for submitting Forms 1094 and 1095 B or C are as follows:
To the IRS
If filing on paper – February 28, 2020
If filing electronically – March 31, 2020
Any employer who would like to file electronically should refer to the IRS for more information on the AIR Program, which requires at least 30 days for testing for first-time users. Please note that employers submitting more than 250 forms must file electronically.
To Individuals
As a result of an extension announced by the IRS, both Form 1095-B and 1095-C are now due to the person identified as the “responsible individual” by March 2, 2020.
Questions?
If you have any questions, please contact your MedCost Benefit Services Account Manager or MedCost Compliance at [email protected]