Final Forms for 2021 ACA Reporting Released
The Internal Revenue Service (IRS) released final 2021 forms for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.
• 2021 Forms 1094-B and 1095-B are the forms that will be used by providers of minimum essential coverage (MEC), including selfinsured plan sponsors that are not applicable large employers (ALEs), to report under Section 6055.
• 2021 Forms 1094-C and 1095-C are the forms that will be used by ALEs to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.
No substantive changes were made to the forms for 2021 reporting. These forms are substantively identical to the final 2020 versions.
Final instructions have not been released yet. However, draft instructions (for Forms 1094-B and 1095-B, as well as for Forms 1094-C and 1095-C) are available, which include updated penalty maximums for 2021. Keep in mind that certain other changes may be made once the instructions are finalized.
Action Steps Employers should become familiar with these forms for reporting for the 2021 calendar year. Note that additional information may become available regarding these forms once final instructions are released.
Jan. 31, 2022 Individual statements for 2021 must be furnished by Jan. 31, 2022.
Feb. 28, 2022 Paper IRS returns for 2021 must be filed by Feb. 28, 2022.
March 31, 2022 Electronic IRS returns for 2021 must be filed by March 31, 2022.