Draft Instructions for 2020 ACA Reporting Released

The Internal Revenue Service (IRS) released draft 2020 instructions related to forms for reporting under Internal Revenue Code (Code) Sections 6055 and 6056. Draft forms for this reporting were released in July 2020.

  • 2020 draft Forms 1094-B and 1095-B and related draft instructions will be used by providers of minimum essential coverage (MEC), including self-insured plan sponsors that are not ALEs, to report under Section 6055.
  • 2020 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.

The draft instructions include a number of changes and clarifications related to 2020 reporting.

  • The deadline for furnishing statements to individuals under Sections 6055 and 6056 has been extended to March 2, 2021.
  • Good faith relief from penalties for reporting incorrect or incomplete information has been extended to 2020 reporting.
  • The “Plan Start Month” box is now required for 2020 reporting.

In addition, the draft Form 1095-C includes several changes, including additional Code Series 1 codes related to offers of individual coverage health reimbursement arrangements (ICHRAs).


Employers should become familiar with these forms and instructions for reporting for the 2020 calendar year. However, these are draft versions only, and should not be filed with the IRS or relied upon for filing.

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