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What Are the Form 1094-C and 1095-C Requirements for Fully Insured Health Plans in 2020?

EBIA  

EBIA  

QUESTION: Our company is an applicable large employer (ALE) that sponsors a fully insured group health plan. We know that in 2020, we have to file Forms 1094-C and 1095-C for the 2019 calendar year. What requirements apply to these forms?

ANSWER: ALEs must report information that the IRS uses to administer employer shared responsibility under Code § 4980H and premium tax credits for individuals. Generally, the IRS needs to know whether the ALE offered minimum essential coverage to at least 95% of its full-time employees and whether the offered coverage provided minimum value and was affordable for purposes of Code § 4980H. Form 1094-C is a transmittal to the IRS that, in combination with Form 1095-C providing individualized information, satisfies these requirements. Form 1095-C is furnished to individuals, but Form 1094-C is not.

There are separate deadlines for filing forms with the IRS and furnishing statements to individuals:

  • Filing With IRS: ALEs must file the 2019 Form 1094-C transmittal (and copies of related Forms 1095-C) with the IRS by February 28, 2020, if they are filing on paper. ALEs filing electronically must file the Form 1094-C transmittal (and copies of related Forms 1095-C) with the IRS by March 31, 2020. Electronic filing is mandatory for ALEs filing 250 or more Forms 1095-C for the 2019 calendar year; otherwise, electronic filing is encouraged, but not required. An automatic 30-day extension is available by filing IRS Form 8809 before the applicable due date.
  • Furnishing to Employees. You must furnish Form 1095-C to each individual who was a full-time employee for any month in 2019. The deadline for furnishing 2019 Form 1095-C to full-time employees is March 2, 2020, reflecting the IRS’s decision (announced in Notice 2019-63—see our Checkpoint article) to provide a blanket 30-day extension of the statutory deadline for 2019 forms. Further extensions of this deadline are not available.

ALEs that sponsor self-insured health plans are also required to report enrollment information for all individuals enrolled in the plan. As the sponsor of a fully insured plan, your company is not subject to this reporting requirement. The insurer providing the coverage will report enrollment information to the IRS.

For more information, see EBIA’s Form 1094/1095 Workbook at Sections IX.C (“Furnishing Employee Statements: Deadline for Furnishing Statements”) and X.B (“Filing With the IRS: Filing Deadlines and Extensions”). See also EBIA’s Health Care Reform manual at Section XXXVI.D (“Information Reporting of Employer-Sponsored Coverage (Applicable Large Employers)”). You may also be interested in our webinar “Form 1094/1095 Reporting for 2019(recorded on 12/4/19).

Contributing Editors: EBIA Staff.

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