IRS Releases Draft 2019 Instructions for Forms 1094/1095

November 20, 2019

Compliance

After a lengthy and unexplained delay, the Internal Revenue Service released drafts of the 2019 Forms 1094-C1095-C and their corresponding instructions on November 13, 2019.  The forms and reporting obligations are basically unchanged from 2018.  There had been speculation that reporting might be streamlined due to the repeal of the individual mandate, but that is not the case.

Minor Changes Only

  • All references to the individual mandate were removed, although the reporting requirements tied to the individual mandate remain.  These are Form 1095-B and Form 1095-C, Part III.
  • Amounts that are annually indexed were adjusted:
    • Penalty amount for failing to file or furnish a correct information return cannot exceed $3,339,000 each in a calendar year.
    • Affordability percentage updated to 9.86%.
  • Due dates for forms:
    • Employers must provide Forms 1095-C to full-time employees (and other employees enrolled in self-insured health coverage) by January 31, 2020.  The IRS historically extends this deadline to early March, but this hasn’t occurred yet.
    • Employers filing less than 250 returns may file paper returns with the IRS by February 28, 2020.
    • Employers filing electronically must file with the IRS by March 31, 2020. An employer who files 250 or more returns must file electronically.

The IRS simultaneously released the drafts for the 2019 Forms 1094-B1095-B and their corresponding instructions. No major changes were made to the B Forms.

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About Chris Beinecke

Christopher Beinecke, J.D., LL.M. has joined MMA in the newly created position of EH&B National Compliance Leader to oversee this effort. Chris is a highly skilled legal practitioner with deep knowledge and years of experience in the areas of compliance and administrative best practices for health and welfare benefit programs. Chris’s legal experience is vast and diverse. Most recently, with the employee benefits practice at international corporate law firm Haynes and Boone, LLP. Prior to that, Chris was a senior compliance consultant for 10 years at Towers Watson and played a major role in the development of the firm’s U.S. health and welfare compliance practice. Chris also worked as an employee benefits lawyer in private practice before entering consulting. Chris received his J.D. from Ohio State University Moritz College of Law, and an LL.M. in taxation from Washington University in St. Louis School of Law. He also holds a B.S. in finance from Miami University Ohio. Chris is licensed to practice in both Texas and Missouri, and is admitted to the U.S. Tax Court.

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