2020 Form 1095-C released: new codes, new deadlines

Pass this info on to Payroll, STAT! IRS just finalized the new 2020 Form 1095-C. And it won’t be the same old, same old.

In fact, not only is the reporting different, but so are the deadlines.

Most changes stem from an IRS law update allowing employers to offer workers individual coverage health reimbursement arrangements (HRAs).

The new form covers HRA plan years starting Jan. 1, 2020.

New codes for the 1095-C

For tax year 2020, Form 1095-C gets updated with brand-new offer codes employers can enter in line 14. You’ll use it to indicate the type of HRA coverage offered to employees.

In all, eight new codes are available for these arrangements, including code 1L, “individual coverage HRA offered to you only with affordability determined by using employee’s primary residence location ZIP code.”

The ZIP code used to determine coverage affordability will now be listed in line 17 of Form 1095-C.

Also, at the beginning of Part II, along with listing a two-digit number for the plan year, employers must include the employee’s age as of Jan. 1, 2020.

New due dates, relief

As in past years, there’s some flexibility with the due date for the 2020 Form 1095-C. The deadline to provide the form to employees has been extended from Jan. 31, 2021, to March 2, 2021.

When submitting returns to the IRS, the deadlines are March 1, 2021, if mailing the forms and March 31, 2021, if they’re transmitted online.

In addition, IRS is again offering relief to employers that include incorrect or incomplete info on Form 1095-C. But you must make a good-faith effort to comply with all other reporting requirements.

Applicable large employers that don’t provide a Form 1095-C to employees who were enrolled in the employer’s self-insured health plan, but weren’t full-time employees during any month of 2020, can receive relief. That’s as long as certain criteria are met.