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

EBIA  

EBIA  

QUESTION: Our company is an applicable large employer (ALE) that sponsors a self-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 (MEC) to at least 95% of its full-time employees, whether MEC was offered to each full-time employee, and whether the offered coverage provided minimum value and was affordable. Form 1094-C is a transmittal to the IRS that, in combination with Form 1095-C providing individualized information, satisfies these requirements.

In addition, ALEs sponsoring self-insured health plans must report enrollment information to the IRS. For employees, this information is reported on Part III of Form 1095-C. For non-employees (e.g., retirees), ALEs may report on Part III of Form 1095-C or may use Form 1095-B instead.

The Form 1095-B or 1095-C is furnished to individuals, but Form 1094-C is not.

There are separate deadlines for filing these 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 deadline.
  • Furnishing to Individuals. You must furnish Form 1095-C to each individual who was a full-time employee for any month in 2019, regardless of whether the individual was offered coverage. For each full-time employee who enrolled in your self-insured plan, you must include enrollment information. The deadline for furnishing the 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.

Although ALEs are required to report enrollment information to the IRS for non-full-time employees and non-employees for 2019, the IRS will not impose penalties against ALEs that fail to furnish statements to individuals enrolled in the ALE’s self-insured health plan if (1) the individual was not a full-time employee for any month in 2019; (2) the ALE posts a notice prominently on its website that individuals may receive a copy of their 2019 Form 1095-B or 1095-C upon request; (3) the website provides an email address and a physical address to which a request may be sent and a telephone number that individuals can call if they have questions; and (4) the ALE furnishes a 2019 Form 1095-B or 1095-C to any individual upon request within 30 days after the request is received.

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)”) and EBIA’s Self-Insured Health Plans manual at Section XXIX.C (“Health Care Reform Reporting Requirements”). 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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