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IRS Releases Draft ACA Reporting Forms for 2020

The IRS released draft 1094-B, 1095-B, 1094-C, and 1095-C forms. The draft 1094-B and 1094-C forms do not contain any substantive changes from the 2019 1094-B and 1094-C forms. Under the instructions section of the draft 1095-B form, an additional code “G” has been added, which would apply on line 8 to designate enrollment in an individual coverage health reimbursement arrangement (ICHRA).

The draft 1095-C form, under Part II, adds a data field for “employee’s age on January 1.” Also, under  Part II,  line 17 has been added for “ZIP code,” which is the ZIP code used for determining affordability of an ICHRA or an employee’s primary residence ZIP code. The instructions for Part II add eight additional codes to reflect offers of ICHRA coverage. The instructions for Part II line 15 add information on how the required employee contribution is calculated to determine affordability of ICHRA coverage.

The IRS has not yet released the separate instructions for these ACA reporting forms.