On July 13, 2020, the Internal Revenue Service (IRS) released draft 2020 forms for reporting under Internal Revenue Code (Code) Section 6056.

2020 draft Forms 1094-C and 1095-C are draft versions of forms that will be used by applicable large employers (ALEs) to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans. Draft instructions for Forms 1094-C and 1095-C have not yet been released.

News Brief headerLate on June 25, 2020, President Donald Trump’s administration asked the Supreme Court to strike down the Affordable Care Act (ACA). If successful, such action would eliminate health coverage for up to 23 million Americans.

The administration’s argument hinges on Congress’ decision in 2017 to remove the individual mandate, the tax penalty for not purchasing insurance.

Legal Update HeaderOn April 9, 2020, the IRS issued Notice 2020-23 to extend key tax deadlines for individuals and businesses in response to the ongoing COVID-19 pandemic.

This new tax relief is provided under Section 7508A of the Internal Revenue Code (Code), which gives the IRS authority to postpone deadlines for taxpayers affected by federally declared disasters.

The Affordable Care Act (ACA) requires applicable large employers (ALEs) to offer affordable, minimum value health coverage to their full-time employees or possibly pay a penalty. This employer mandate is also known as the “employer shared responsibility” or “pay or play” rules.

ALEs can use one of two methods to determine whether employees are full time under the employer shared responsibility rules:
  • The monthly measurement method determines full-time status for each calendar month based on the employee’s hours of service in that month.
  • The look-back measurement method determines full-time status for a longer period of time based on average hours of service during a prior period.