The IRS has released final 2019 versions of Forms 1094-C, 1095-C, 1094-B, and 1095-B that employers will use in early 2020 to report on the group health insurance coverage they offered during the 2019 calendar year. Instructions on how to complete Forms 1094-C and 1095-C and Forms 1094-B and 1095-B for the 2019 calendar year have also been released. The 2019 forms and instructions are substantially similar to the 2018 versions.

Note that Section 6055 reporting continues to be required, despite the fact that the individual mandate penalty has been reduced to $0. However, the IRS has already provided transition relief from penalties related to failures to furnish 2019 forms to individuals under Section 6055, under certain circumstances. Under this relief, employers will only have to provide Form 1095-B to covered individuals upon request. Forms 1094-B and 1095-B must still be filed with the IRS.

For 2019 calendar year reporting, individual statements must be furnished by March 2, 2020, and IRS returns must be filed by Feb. 28, 2020 (or March 31, 2020, if filed electronically).