On July 13, 2020, the Internal Revenue Service (IRS) released 2020 draft Forms 1094-C and 1095-C. Draft instructions have not yet been released, and Forms 1094-B and 1095-B and related draft instructions have not been released at this time.
Draft Forms 1094-C and 1095-C are substantially similar to the final 2019 versions. However, certain additions were made to the 2020 draft Form 1095-C related to ICHRAs. Beginning in 2020, employers of all sizes may implement a new HRA design—an ICHRA—to reimburse their eligible employees for insurance policies purchased in the individual market or Medicare premiums.
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.
Keep in mind that the IRS may make additional changes to these forms before releasing final 2020 versions.