Draft Forms for 2020 ACA Reporting Disclosed

On July 13, 2020, the IRS released 2020 draft Forms 1094-C and 1095-C. The drafts will be used by applicable large employers (ALEs) to report under Section 6056, as well as combined sections 6055 and 6056 for ALEs who sponsor self-insured plans. Draft instructions for Forms 1094-C and 1095-C have not yet been released.

The Affordable Care Act (ACA) created these reporting requirements under Code Sections 6055 and 6056. To comply with these Code Sections, certain employers must provide information to the Internal Revenue Service (IRS) about the health plan coverage they either offer, do not offer, or provide to their employees.

Draft Forms 1094-C and 1095-C are vastly similar to the final 2019 versions; however, Form 1095-C includes:

  • A new section to enter the employee’s age on January 1;
  • Additional codes in Code Series 1 related to offers of individual coverage health reimbursement arrangements (ICHRAs); and
  • A new section to enter the zip code used to determine affordability for an ICHRA if one was offered to the employee.

Draft Forms 1094-B and 1095-B for reporting under Section 6055 have not been released at this time. When finalized, the forms will be used by entities reporting under Section 6055, including self-insured plan sponsors that are not ALEs.

Important Dates

  • Individual statements for 2020 must be furnished by January 31, 2021.
  • IRS returns for 2020 must be filed by February 28, 2021. If filed electronically, the deadline is March 31, 2021.

Keep in mind, the IRS does not release draft forms until they believe they have incorporated all changes (except when explicitly stated). Forms and instructions are generally subject to Office of Management and Budget (OMB) approval before the final forms are released.

For additional details regarding the draft forms, click here.


Trust the Creative Benefits, Inc. team to keep you updated as additional information is released. Questions? Contact our team at 866-306-0200 or solutions@creativebenefitsinc.com.