The IRS recently published the draft instructions for the 2020 Forms 1094-B and 1095-B. As a reminder, small employers with self-insured health coverage are responsible for completing this reporting by the following deadlines:
- Furnishing deadline for 2020 Forms 1095-B is March 2, 2021 (extended from January 31, 2021 per IRS Notice 2020-76).
- Filing deadline for 2020 Forms 1094-B and 1095-B is February 28, 2021, for paper filings, and March 31, 2021, for electronic filings.
Most of the reporting requirements for the 2020 Forms 1094-B and 1095-B remain unchanged. However, if a small employer offered an individual coverage health reimbursement arrangement (ICHRA) during the 2020 calendar year, it will report a new code “G” on line 8 of Form 1095-B to identify this type of coverage. As background, ICHRAs became available to employers of any size as a means to reimburse employees for costs associated with individual policies or Medicare for plan years beginning on or after January 1, 2020.
Finally, the draft instructions also remind reporting entities subject to these reporting requirements that the IRS will not impose any penalties for failure to furnish Forms 1095-B if they meet the following requirements: (1) prominently post a notice on their website stating that responsible individuals may receive a copy of their 2020 Form 1095-B upon request, accompanied by an e-mail address, physical address, and contact phone number; and (2) furnish a 2020 Form 1095-B within 30 days of the date requested.
ETC will continue to monitor the release of any final forms and instructions as they become available. If you would like more information about these reporting requirements, ETC Companies has resources to help.