Final Forms & Instructions for 2020 ACA Reporting Released

The Internal Revenue Service (IRS) has released final forms and instructions for 2020 ACA reporting under Internal Revenue Code Sections 6055 and 6056. Prior to finalizing, draft forms were released this past July, with additional revisions made this month to both the forms and instructions.

The final forms and instructions require certain employers to provide information to the IRS about their health plan coverage and include various changes and clarifications from prior reporting years.

  • 2020 Form 1094-B and Form 1095-B, as well as related instructions are used by providers of minimum essential coverage (MEC), including self-insured plan sponsors that are not ALEs, to report under Section 6055.
  • 2020 Form 1094-C and Form 1095-C, as well as related instructions are used by ALEs to report under Section 6056. ALEs who sponsor self-insured plans will use these forms to report for combined Section 6055 and 6056.
  • Individual statements must be furnished by March 2, 2021. IRS returns must be filed by February 28, 2021; if filing electronically, the deadline is March 31, 2021.
  • Changes were also made to Forms 1095-B and 1095-C related to offers of individual coverage health reimbursement arrangements (ICHRAs).

For reference, the IRS has provided Q&As on Section 6055 and Q&As on Section 6056.

To avoid costly penalties and remain compliant with the ACA, we encourage employers to become familiar with these final forms and instructions, as well as deadlines and important dates. The IRS, however, has declared that information returns under Sections 6055 and 6056 may continue to be filed after the filing deadline (both on paper and electronically). If the deadline is missed, employers should continue to make efforts to file their returns as soon as possible.


It is our goal to guide you through ongoing compliance updates. If you have questions, contact our team at 866-306-0200 or solutions@creativebenefitsinc.com.