2020 Employer Reporting

The IRS made the final 2020 employer reporting forms and instructions available. The Form 1094-Cs are pretty much identical to last year. The Form 1095-Cs were modified slightly, primarily to facilitate reporting by employers who offered individual coverage HRAs (ICHRAs) in 2020. The minor changes for the Form 1095-C as follows:

• For the first time, employers will be required to report the plan year start month in Part II of the Form 1095-Cs. This was previously optional.
• In addition, applicable large employers who offered ICHRAs during 2020 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 will also have to provide zip code information on Line 17.

The penalty for failing to report, for providing incorrect information, or for failing to provide copies to full-time employees and covered individuals has increased from $270/month (maximum of $3,339,000) to $280/month (maximum of $3,392,000) for 2020.

Applicable large employers and employers who offered self-funded group health plan coverage during 2020, including ICHRA coverage, must provide 1095s to full-time employees and covered individuals no later than March 2, 2021 (in accordance with the extended deadline). Form 1094 and Form 1095s must be filed with the IRS no later than March 1, 2021 if they are mailed; the deadline is March 31, 2021 for forms filed electronically. 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.