DRAFT FORMS FOR 2019 ACA REPORTING RELEASED

New Compliance Update
Overview

On Nov. 13, 2019, the Internal Revenue Service (IRS) released draft 2019 forms and instructions for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.

2019 draft Forms 1094-C and 1095-C (and related draft instructions) will be used by applicable large employers (ALEs) to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.

2019 draft Forms 1094-B and 1095-B (and related draft instructions) will be used by entities reporting under Section 6055, including self-insured plan sponsors that are not ALEs.

The draft 2019 forms and instructions are substantially similar to the final 2018 versions. Note that Section 6055 reporting continues to be required, despite the fact that the individual mandate penalty has been reduced to $0.

ACTION STEPS

Employers should become familiar with these forms for reporting for the 2019 calendar year. However, these forms and instructions are draft versions only, and should not be filed with the IRS or relied upon for filing

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