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Attention Employers that Sponsor an ICHRA!!!

HitesmanLaw, PAClient AlertsFebruary 19, 2021

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.

Previous post Upcoming EBIA Webinars: Self-Audit Your Group Health Plan Compliance | Governmental and Church Group Health Plans: What Rules Apply? Next post Last Minute Relief: Interpretation of Delay Adds Lots of Work & Additional Exposure

Blog

  • Important Relief for Filing 1094-1095 Forms for 2020 Calendar Year
  • April 22, 2020: DOL Ends Temporary Non-Enforcement of Paid Leave Protections to Help American Workers During Coronavirus Pandemic
  • CAUTION:  Self-Funded Plan Documents – recent case decision
  • EBIA’s 19th Annual Advanced Cafeteria Plans and Benefits Conference
  • 2018 HSA Contribution Amounts and HDHP Requirements

Client Alerts

  • Last Minute Relief: Interpretation of Delay Adds Lots of Work & Additional Exposure
  • Attention Employers that Sponsor an ICHRA!!!
  • Upcoming EBIA Webinars: Self-Audit Your Group Health Plan Compliance | Governmental and Church Group Health Plans: What Rules Apply?
  • The CAA: The Legislative Gift that Keeps on Giving
  • Important Relief for Filing 1094-1095 Forms for 2020 Calendar Year

Upcoming Seminars

No events planned yet.

About HitesmanLaw

As a leader in employee benefits law, Darcy Hitesman founded HitesmanLaw in order to help public and private employers, insurers and third-party administrators nationwide stay informed and minimize the risk of non-compliance issues.

HitesmanLaw provides a wealth of legal experience to their clients in the areas of ERISA, COBRA, HIPAA, Health Care Reform, welfare plans, cafeteria plans, HRAs, and VEBAs.

Client Alerts

  • Last Minute Relief: Interpretation of Delay Adds Lots of Work & Additional Exposure
  • Attention Employers that Sponsor an ICHRA!!!
  • Upcoming EBIA Webinars: Self-Audit Your Group Health Plan Compliance | Governmental and Church Group Health Plans: What Rules Apply?
  • The CAA: The Legislative Gift that Keeps on Giving

Upcoming Speaking Engagements

No events planned yet.

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