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ACA Reporting - Draft 2019 Forms and Instructions

December 11, 2019

The IRS has released draft versions of the Form 1094/1095 information returns and instructions for the 2019 tax year (for filing in early 2020), which are used by employers and other reporting entities to report information on healthcare coverage as required by the Affordable Care Act (ACA). These are draft versions subject to change with the final versions.

Health Insurance Coverage Reporting by Insurers and Sponsors of Self-funded Plans  

Employer Health Insurance Reporting Requirement  

The draft 2019 Forms and Instructions indicate that the reporting process for 2019 will likely remain largely unchanged from the calendar year 2018. Forms to individuals must be furnished by January 31, 2020. Electronic filing of the Forms with the IRS is due by March 31, 2020; or, February 28, 2020, if filing by paper (only for employers filing fewer than 250 returns per year).  Employers and plan sponsors should take note of the timing requirements and review the information reporting requirements through IRS resources available at the Applicable Large Employer Information Center. Employers should also continue to be on the lookout for IRS penalty letters or notices related to past ACA filings and should immediately present any materials received to their ACA reporting vendors, legal counsel and qualified tax advisers.

We will continue to monitor developments on new and revised employer obligations as they take shape over time, and we will provide an update on the final Forms once they are released. Should you have questions about this or any aspect of federal health insurance reform, contact your Conner Strong & Buckelew account representative toll-free at 1-877-861-3220. For a complete list of Legislative Updates issued by Conner Strong & Buckelew, visit our online Resource Center.