On July 13, 2020, the Internal Revenue Service (IRS) released draft 2020 forms for reporting under Internal Revenue Code (Code) Section 6056. 2020 draft Forms 1094-C and 1095-C are draft versions of forms that 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. Draft instructions for Forms 1094-C and 1095-C have not yet been released.

In addition, 2020 draft forms for reporting under Section 6055 (Forms 1094-B and 1095-B, and related draft instructions) have not been released at this time. These forms, when finalized, will be used by entities reporting under Section 6055, including self-insured plan sponsors that are not ALEs.

Draft Forms 1094-C and 1095-C are substantially similar to the final 2019 versions. However, the draft Form 1095-C includes:

·         A new section to enter the employee’s age on Jan. 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.