If you are an employer that sponsored an Individual Coverage Health Reimbursement Arrangement (ICHRA) during the 2020 calendar year, you are required to comply with the ACA annual filing requirements. Even smaller employers must file. The deadlines are approaching soon!
For an ALE, the IRS requires reporting of ICHRAs for an applicable large employer (ALE) on Form 1095-C. The 2020 Form 1095-C generally must be furnished to employees by March 2, 2021. The form, along with the transmittal Form 1094-C must be filed with the IRS by March 1, 2021 (because February 28 falls on a Sunday), if filed on paper (and by March 31, 2021, if filed electronically).
For a non-ALE (small employer less than 50), the IRS requires reporting of ICHRAs for small employer ICHRA plans on Form 1095-B. The 2020 Form 1095-B generally must be furnished to employees by March 2, 2021. But a special rule allows the employer to post on its website if certain conditions are met. The form, along with the transmittal Form 1094-B must be filed with the IRS by March 1, 2021 (because February 28 falls on a Sunday), if filed on paper (and by March 31, 2021, if filed electronically).
There are penalties for not filing and not filing timely. Failure to file is not part of the good faith relief.
Please let us know if you have questions or would like assistance completing the forms.
