IRS Releases Forms 1094-C, 1095-C

IRS Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, is used annually by an applicable large employer (ALE) to report health coverage offered to employees. In conjunction with Form 1095-C, an ALE is required to use IRS Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, to report coverage information to the IRS.

For past years, the IRS provided relief to employers that attempted to comply with the reporting requirements in good faith. The relief is no longer applicable for the 2021 calendar year. In addition, while Form 1094-C has not been amended, Form 1095-C now includes two new codes to describe coverage provided through an individual coverage health reimbursement arrangement (ICHRA). These new codes apply to ICHRA coverage where the affordability percentage was applied using the employee’s residence or employment zip code as follows.

• 1T – ICHRA offered to employee and spouse (no dependents) with affordability determined using employee’s primary residence zip code
• 1U – ICHRA offered to employee and spouse (no dependents) using employee’s primary employment site zip code affordability safe harbor

Form 1095-C must be provided to employees by January 31, 2022. Form 1094-C must be filed with the IRS by February 28, 2022, if filing by paper, or March 31, 2022, if filing electronically. It is not expected that these deadlines will be extended.