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Benefits Brief: 2020 ACA Reporting

November 5, 2020


The reporting requirements under the Affordable Care Act (ACA) have been in effect since 2015.  Many employers, mainly large employers, are already familiar with the rules.  However, some employers, particularly those that have grown in size, may lack clarity regarding their reporting obligations under the law.  As the deadlines for 2020 ACA reporting roll near, it is important to review the basics of reporting, including any changes that may be applicable for the 2020 reporting year.


Basics of Reporting

The ACA created two federal reporting requirements under Internal Revenue Code (Code) Sections 6055 and 6056.


Which Employers are Required to Report?


Reporting Forms


On October 15, 2020, the IRS released final versions of the 2020 reporting forms and instructions.  There were new data fields on the forms for ALEs who implemented an Individual Coverage HRA (ICHRA). Also, there were several other changes made that impact all ALEs (e.g., ALEs must now enter a two-digit number for the plan start month).


Deadlines for Filing

The due date for furnishing the 2020 Form 1095-B and 1095-C to individuals was extended from January 31, 2021 to March 2, 2021 (see our Benefits Bulletin).  Employers can deliver the 1095-Cs to individuals by mail, in-person or electronically (with consent).  There was no extension of the deadline for filing with the IRS.  This deadline remains March 1, 2021 (March 31, 2021, if filing electronically)Electronic filing is mandatory if an employer is filing 250 or more Forms 1095-C and must be done via the ACA Information Returns (AIR) System.



If an employer fails to furnish the necessary forms to individuals, or files incomplete or inaccurate ACA filing forms with the IRS, the IRS may impose penalties of up to $280 per form per failure.  However, the IRS will not impose penalties for incomplete or inaccurate forms if the employer can show it made “good-faith efforts” to comply with the information reporting requirements (which requires the forms to be filed timely with the IRS).  This relief extends to the 2020 forms due in 2021 but will not be extended for the 2021 forms due in 2022.


Next Steps for Employers





Additional Resources






This Benefits Brief is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.

Posted by in Blog, Health & Benefits, Human Resources

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