Final 2020 Forms 1094-C & 1095-C Issued and Deadline Extended for 2020 Forms 1095-C

Issued date: 10/23/20

Issued date: 10/23/20

On October 2, 2020, the IRS issued Notice 2020-76, which provides:

  • An extension of time, until March 2, 2021, for employers to provide Forms 1095-C to their full-time employees and other individuals; and

  • A final extension of relief from penalties for the 2020 reporting year for employers and other entities that make good-faith efforts to comply with the reporting requirements.

Notice 2020-76 does not, however, extend the deadline to provide completed Forms 1094-C and 1095-C (and Forms 1094-B and 1095-B) to the IRS (as described in Q/A-2 below). Nor does it provide any relief from providing Forms 1095-C to full-time employees (“FTEs”). This means that all Applicable Large Employers (“ALEs”) must continue to provide Form 1095- C to any employee that was full time for any month of 2020.

However, the Notice provides an alternative furnishing method for Form 1095-B (and in some cases Form 1095-C), with relief from the 2020 Section 6055 reporting penalty, for:

  • Insurance carriers that are otherwise required to furnish Form 1095-B to covered individuals for calendar year 2020;

  • Employers with self-funded health plans that are otherwise required to furnish Form 1095-B to covered individuals for calendar year 2020 (generally employers with fewer than 50 employees with a self-funded plan); and

  • Employers with self-funded health plans that are otherwise required to furnish Form 1095-C to covered individuals who were not full-time employees in any month of calendar year 2020.

Briefly, the alternative furnishing method allows carriers (and in some cases employers) to avoid 2020 Section 6055 penalties associated with a failure to furnish the applicable form to covered individuals by posting information to a website and timely providing the completed applicable Form upon request.

The following FAQs provide additional details.

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