OVERVIEW

On Dec. 9, 2019, the Internal Revenue Service (IRS) released final 2019 forms and instructions for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.

  • 2019 Forms 1094-C and 1095-C (and instructions) 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 Forms 1094-B and 1095-B (and instructions) will be used by entities reporting under Section 6055, including self-insured plan sponsors that are not ALEs.

The 2019 forms and instructions are substantially similar to the 2018 versions.Note that Section 6055 reporting is still required, despite the fact that the individual mandate penalty has been reduced to $0, although transition relief from penalties is available in certain circumstances.

 

ACTION STEPS

Employers should become familiar with these forms for reporting for the 2019 calendar year. Individual statements must be furnished by March 2, 2020, and IRS returns must be filed by Feb. 28, 2020 (March 31, 2020, if filed electronically).

 

HIGHLIGHTS

  • Final forms and instructions for 2019 reporting under Section 6055 and Section 6056 are now available.
  • These forms and instructions are substantially similar to the 2018 versions.
  • Section 6055 reporting continues to be required, although limited penalty relief is available.

 

IMPORTANT DATES

  • March 2, 2020 |¬†Individual statements for 2019 must be furnished by March 2, 2020.
  • February 28, 2020 | IRS returns for 2019 must be filed by Feb. 28, 2020 (March 31, 2020, if filed electronically).

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Additional Compliance Alert:

DOL Issues Model Health Care Transparency Disclosure Documents

 

OVERVIEW

The Department of Labor (DOL) has released the following three model disclosure documents related to a November proposed rule on transparency in coverage for group health plans and health insurers in the individual and group markets.

These documents were issued as appendices to the proposed rule, and are intended to be used to satisfy its disclosure requirements.

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