Benefits Buzz August 2022

Draft Forms for 2022 ACA Reporting Released

The IRS released draft 2022 forms for reporting under Internal Revenue Code Sections 6055 and 6056. Draft instructions for these forms have not yet been released.

  • 2022 draft Forms 1094-B and 1095-B are drafts of the forms used by providers of minimum essential coverage, including self-insured plan sponsors that are not applicable large employers (ALEs), to report under Section 6055.
  • 2022 draft Forms 1094-C and 1095-C are drafts of forms ALEs use to report under Section 6056 and for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.

Form 1095-B no longer includes references to the individual mandate penalty in the “Instructions for Recipients” section. No other changes were made to the 2022 draft forms. However, certain changes may be made once the forms are finalized or when draft or final instructions are released.

Reporting Deadlines

Paper IRS returns for 2022 must be filed by Feb. 28, 2023, while electronic returns must be filed with the IRS by March 31, 2023.

A 2021 proposed rule extended the annual furnishing deadlines under both Sections 6055 and 6056 for an additional 30 days. As a result, individual statements for 2022 must be furnished by March 2, 2023. Reporting entities are encouraged to furnish statements as soon as they are able.

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