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IRS Form 1095-C for ACA Reporting in 2021

Form 1094-C is unchanged from last year.

Form 1095-C changes include:

Employee’s age as of January 1 of the reporting year

The IRS will now require an entry for the “Age” of each employee as of January 1, 2020. This will be in Part 2 on the 1095-C form. Use either an age or the full birth date and our 1099FIRE software will automatically convert the birthdate to age.

Employee age is not discussed in the “Instructions for Recipient” part of the draft Form 1095-C. Its possible employee age will only need to be completed by employers who utilized individual coverage health reimbursement arrangements. If an employer utilized individual coverage HRAs, the employer will need to know the employee’s date of birth to be able to complete this new section.

New line in Part II which asks about the ZIP code

In Part II of Form 1095-C form, a new Box 17 ZIP Code has been added to report information. You fill out the zip code if you are using codes 1L through 1S in Box 14 which represents a Health Reimbursement Arrangement (HRA).

New offer codes which can be entered on line 14

The below offer codes are new on line 14 for tax year 2020.

1L. Individual coverage health reimbursement arrangement (HRA) offered to you only with affordability determined by using employee’s primary residence location ZIP Code.

1M. Individual coverage HRA offered to you and dependent(s) (not spouse) with affordability determined by using employee’s primary residence location ZIP Code.

1N. Individual coverage HRA offered to you, spouse and dependent(s) with affordability determined by using employee’s primary residence location ZIP Code.

1O. Individual coverage HRA offered to you only using the employee’s primary employment site ZIP Code affordability safe harbor.

1P. Individual coverage HRA offered to you and dependent(s) (not spouse) using the employee’s primary employment site ZIP Code affordability safe harbor.

1Q. Individual coverage HRA offered to you, spouse and dependent(s) using the employee’s primary employment site ZIP Code affordability safe harbor.

1R. Individual coverage HRA that is NOT affordable offered to you; employee and spouse or dependent(s); or employee, spouse, and dependents.

1S. Individual coverage HRA offered to an individual who was not a full-time employee.

Form 1095-C is now a 2 page form where Boxes 1-17 are listed on page 1 and the covered individuals are shown on page 2.

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