Draft Forms for 2019 ACA Reporting Released

Over the years, the Affordable Care Act (ACA) has created reporting requirements under Code Sections 6055 and 6056. These rules require certain employers to provide information to the Internal Revenue System (IRS) about the health plan coverage they either offer, don’t offer, or provide to their employees.

2019 Draft Forms & Instructions

On November 13, 2019, the IRS released draft 2019 forms and instructions for reporting under Internal Revenue Code Sections 6055 and 6056.

The draft forms and instructions are similar to the final 2018 versions, despite the individual mandate penalty being reduced to $0 under Section 6055.

  • 2019 draft Forms 1094-C and 1095-C will be used by applicable large employers (ALEs) to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.
  • 2019 draft Forms 1094-B and 1095-B will be used by entities reporting under Section 6055, including self-insured plan sponsors that are not ALEs.

Each reporting entity must annually file all of the following with the IRS:

  • A separate statement (Form 1095-B or Form 1095-C) for each individual who is provided with minimum essential coverage, or for each full-time employee.
  • A transmittal form (1094-B or Form 1094-C) for all the returns filed for a given calendar year.
  • Reporting entities must furnish related statements (Form 1095-B or 1095-C) to individuals as well.

Keep in mind, these are drafted versions, meaning the IRS may make additional changes to these forms and instructions before releasing the final 2019 versions.

Important Dates

  • Forms must be generally filed with the IRS no later than February 28, 2020; or March 31, 2020 if filed electronically.
  • Individual statements for 2019 must be furnished on or before January 31, 2020.

Employers should become familiar with these forms for reporting for the 2019 calendar year to avoid potential penalty. According to the IRS, information returns under these sections may continue to be filed after the filing deadline. If employers miss the filing deadline, they should continue to make efforts to file their returns as soon as possible to the IRS.

For more information on reporting under Code Sections 6055 and 6056, click here.


Contact the Creative Benefits Team at 866-306-0200 or email us at solutions@creativebenefitsinc.com with any questions.