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IRS Releases 2020 ACA Reporting Forms, Instructions

BY: Jyme Mariani, Esq. | 10/22/20

The IRS released the 2020 Affordable Care Act (ACA) forms and instructions. The forms for tax year 2020 have few changes: Form 1094-B, Transmittal of Health Coverage Information Returns; Form 1095-B, Health Coverage; Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns; Form 1095-C, Employer-Provided Health Insurance Offer and Coverage; 2020 Instructions for Forms 1094-B and 1095-B; and 2020 Instructions for Forms 1094-C and 1095-C.

Changes Made to Add HRAs

For plan years beginning on or after January 1, 2020, employers may offer health reimbursement arrangements (HRAs) integrated with individual health insurance coverage or Medicare, subject to certain conditions (individual coverage HRAs). On September 30, 2019, the IRS issued proposed regulations clarifying the application of the employer-shared responsibility provisions in IRC §4980H to individual coverage HRAs and providing safe harbors to apply the provisions to individual coverage HRAs.

The following changes were made:

  • Form 1095-B. A new code G must be entered on Line 8 to identify an individual coverage HRA.
  • Form 1095-C. Line 17 has been moved to Part II and is used to enter a ZIP code. New codes (1L-1S) have been added for individual coverage HRAs on Lines 14-17. More lines for additional entries have been added to Part III.

Due Dates Extended

On October 2, the IRS extended the due date for furnishing 2020 Forms 1095-B and 1095-C to employees from January 31 to March 2 [Notice 2020-76, 10-2-20]. The deadline to file these returns with the IRS remains March 1, if filing on paper, or March 31, if filing electronically.

To learn more about federal and state laws, regulations, and information to keep your company's payroll operations in compliance, check out Payroll Source Plus!


Jyme Mariani, Esq., is Managing Editor of Payroll Currently and Payroll Information Resources for the APA.