IRS Extends Deadline for Furnishing Form 1095-C, Extends Good-Faith Transition Relief

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This Form 1094-C should be identified as the Authoritative Transmittal on line 19, and the remainder of the form completed as indicated in the instructions for line 19, later. As a result, the permissive 30-day extension is not available for the 2020 reporting year. The due date for filing the forms with the IRS was not extended and remains March 1, 2021 (March 31, 2021 if filed electronically). An employee is an individual who is an employee under the common-law standard for determining employer–employee relationships.

Do not file a return correcting information on a Form 1094-C that is not the Authoritative Transmittal. To develop software for use with the AIR system, software developers, transmitters, and issuers, including ALE Members filing their own Forms 1094-C and 1095-C, should use the guidelines provided in Pub. 5165 along with the Extensible Markup Language (XML) Schemas published on IRS.gov.

Legal Disclaimer

Enter the name and telephone number of the person to contact who is responsible for answering any questions from the IRS regarding the filing of, or information reported on, Form 1094-C. Enter the name and telephone number of the person to contact who is responsible for answering any questions from the IRS regarding the filing of, or information reported on, Form 1094-C or 1095-C. This may be different than the contact information on line 10 of Form 1095-C. See the charts for examples of errors and step-by-step instructions for filing corrected returns.

  • An HRA is a type of account-based health plan that employers can use to reimburse employees for their medical care expenses.
  • For purposes of column (a), an employee in a Limited Non-Assessment Period is not counted in determining whether minimum essential coverage was offered to at least 95% of an ALE Member’s full-time employees and their dependents.
  • For additional information, including examples about reporting offers of COBRA continuation coverage and post-employment coverage, go to IRS.gov/Affordable-Care-Act/Employers/Questions-and-Answers-about-Information-Reporting-by-Employers-on-Form-1094-C-and-Form-1095-C.
  • This Form 1094-C should be identified as the Authoritative Transmittal on line 19, and the remainder of the form completed as indicated in the instructions for line 19, later.
  • Joining the agency in 2014, Chuck is a licensed insurance executive with a focus on commercial insurance and emergency service organizations.

An ALE Member makes an offer of health coverage to an employee for the plan year if it continues the employee’s election of coverage from a prior year but provides the employee an effective opportunity to opt out of the health coverage. An employee who is treated as having been offered health coverage, including an individual coverage HRA, for purposes of section 4980H (even though not actually offered) is treated as offered minimum essential coverage for this purpose. For different rules for purposes of reporting offers of coverage on Form 1095-C, see the specific instructions for Form 1095-C, Part II, line 14. We ask for the information on these forms to carry out the Internal Revenue laws of the United States and the Patient Protection and Affordable Care Act. Our legal right to ask for the information on this form is Internal Revenue Code sections 6055, 6056, 4980H, and their regulations.

Other Reporting Penalties

irs extends 2020 form 1095 furnishing deadline and other relief

An employee does not include a sole proprietor, a partner in a partnership, an S corporation shareholder who owns at least 2% of the S corporation, a leased employee within the meaning of section 414(n), or a worker that is a qualified real estate agent or direct seller. An ALE Member is a single person or entity that is an ALE, or if applicable, each person or entity that is a member of an Aggregated ALE Group. A person or entity that does not have employees or only has employees with no hours of service (for example, only employees whose entire service consists of work outside of the United States that does not count as hours of service under section 4980H) is not an ALE Member. References to 9.5% in the section 4980H affordability safe harbors and Qualifying Offer Method are applied based on the percentage as indexed for purposes of applying the affordability thresholds under section 36B (the premium tax credit).

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A dependent is an employee’s child, including a child who has been legally adopted or legally placed for adoption with the employee, who has not reached age 26. A child reaches age 26 on the 26th anniversary of the date the child was born and is treated as a dependent for the entire calendar month during which he or she reaches age 26. For this purpose, a dependent does not include stepchildren, foster children, or a child that does not reside in the United States (or a country contiguous to the United States) and who is not a U.S. citizen or national. Enter the number of full-time employees for each month, but do not count any employee in a Limited Non-Assessment Period. If the number of full-time employees (excluding employees in a Limited Non-Assessment Period) for a month is zero, enter -0-.

Privacy Act and Paperwork Reduction Act Notice.

However, there are some significant updates to the 1095-C draft form from the 2019 version. Paylocity will provide updates once final forms and instructions are released. This information is an educational summary not intended to serve as legal or financial advice. Consult your own legal or tax professional to ensure compliance with all law applicable to your specific circumstances.

  • You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless the form displays a valid OMB control number.
  • If you are required to file 10 or more information returns during the year, you must file the forms electronically.
  • An ALE Member that is eligible to use the Qualifying Offer Method may use the alternative method of furnishing Form 1095-C only for a full-time employee who (1) received a Qualifying Offer for all 12 months of the calendar year, and (2) did not enroll in employer-sponsored, self-insured coverage.

For purposes of reporting, an offer to a spouse includes an offer to a spouse that is subject to one or more reasonable, objective conditions, regardless of whether the reasonable, objective conditions are satisfied. For example, an offer of coverage that is available to a spouse only if the spouse certifies that the spouse does not have access to health coverage from another employer is treated as an offer of coverage to the spouse for reporting purposes. Note that this treatment is for reporting purposes only, and will generally not affect the spouse’s eligibility for the premium tax credit if the spouse did not meet the condition and therefore did not have an actual offer of coverage. A conditional offer to a spouse is reported by entering code 1J or 1K (as applicable) on line 14 of Form 1095-C. An offer to a dependent does not include an offer to a dependent that is subject to one or more reasonable, objective conditions unless the dependent satisfies the conditions and the dependent actually had an offer of coverage. In addition, an offer of coverage is treated as made to an employee’s dependents only if the offer of coverage is made to an unlimited number of dependents regardless of the actual number of dependents, if any, an employee has during any particular calendar month.

Business Insurance

A code must be entered for each calendar month, January through December, even if the employee was not a full-time employee for 1 or more of the calendar months. Enter the code identifying the type of health coverage actually offered by the ALE Member (or on behalf of the ALE Member) to the employee, if any. If the employee was not actually offered coverage, enter code 1H (no offer of coverage) on line 14. Employee is in a health coverage waiting period (and an employer shared responsibility payment could not apply with respect to Employee, because Employee is in a Limited Non-Assessment Period) until April 1 and is a full-time employee for the remainder of the calendar year. Employer makes a Qualifying Offer to Employee for coverage beginning on April 1 and for the remainder of the calendar year. Employer is eligible to use the Qualifying Offer method because it has made a Qualifying Offer to at least one full-time employee for all months in which both (1) the employee was a full-time employee, and (2) an employer shared responsibility payment could apply with respect to the employee.

Instead, the ALE Member may furnish a copy of Form 1095-C as filed with the IRS (with or without the statement described earlier). If you are a DGE that is filing Form 1094-C, a valid EIN is required at the time the return is filed. If the DGE does not have an EIN when filing Form 1094-C, it can get an EIN by applying online at IRS.gov/EIN or by faxing or mailing a completed Form SS-4. An ALE Member must furnish a Form 1095-C to each of its full-time employees by March 3, 2025, for the 2024 calendar year.

irs extends 2020 form 1095 furnishing deadline and other relief

An employee should be counted as a full-time employee for a month if the employee satisfied the definition of “full-time employee” under the monthly measurement method or the look-back measurement method (as applicable) on any day of the month. See Full-time employee and Limited Non-Assessment Period in the Definitions section. Be sure to use the section 4980H irs extends 2020 form 1095 furnishing deadline and other relief definition and not any other definition of the term “full-time employee” that you may use for other purposes. If you fail to file correct information returns or fail to furnish a correct recipient statement, you may be subject to a penalty. However, you are not required to file corrected returns for missing or incorrect TINs if you meet the reasonable cause criteria. 1586, Reasonable Cause Regulations and Requirements for Missing and Incorrect Name/TINs on Information Returns.

For purposes of reporting on Forms 1094-C and 1095-C, an employee in a Limited Non-Assessment Period is not considered a full-time employee during that period. Over the summer, the IRS published the draft Form 1094-C and draft Form 1095-C for the 2020 tax year. While the forms are not the final version, currently the Form 1094-C remains unchanged.

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