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Notice 2020-76: Relief for health coverage information reporting (now due March 2, 2021)

Relief for health coverage information reporting

The IRS today released an advance version of Notice 2020-76 that extends the due date—from January 31, 2021, to March 2, 2021—for certain 2020 information reporting about health coverage under sections 6055 and 6056.


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Notice 2020-76 [PDF 71 KB] extends the due dates under sections 6055 and 6056 to March 2, 2021, for insurers, self-insuring employers, applicable large employers, and certain other providers of minimum essential coverage to furnish to individuals the 2020 Form 1095-B, Health Coverage, and the 2020 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage. 

The notice provides that the IRS will not impose a penalty under section 6722 for failures to furnish a Form 1095-B to responsible individuals and also provides a final extension of transitional good-faith relief from section 6721 and 6722 penalties to the 2020 information reporting requirements under sections 6055 and 6056.

In general:

  • Section 6055 requires health insurance issuers, self-insuring employers, government agencies, and other providers of minimum essential coverage to file and furnish annual information returns and statements regarding coverage provided.
  • Section 6056 requires applicable large employers (generally those with 50 or more full-time employees, including full-time equivalent employees, in the previous year) to file and furnish annual information returns and statements relating to the health insurance, if any, that the employer offers to its full-time employees.

According to Notice 2020-76, the IRS and Treasury Department have determined that a “substantial number of employers, insurers, and other providers of minimum essential coverage need additional time” to complete the 2020 Forms 1095-B and 1095-C that are to be furnished to individuals. 

Notice 2020-76 cautions that it does not extend the due date for filing Forms 1094-B, 1095-B, 1094-C or 1095-C for 2020, and Notice 2020-76 does not affect the provisions regarding an automatic extension of time for filing information returns; the automatic extension remains available under the normal rules for employers and other coverage providers that submit a Form 8809 on or before the due date; and does not affect the provisions regarding additional extensions of time to file.

With today’s notice, the IRS and Treasury Department are requesting comments as to whether and how the reporting requirements under section 6055 may need to change, if at all, for future years. Comments are requested by February 1, 2021.

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