IRS Releases 2021 Forms 1094-C and 1095-C

Robert Beck
November 16, 2021

The IRS recently released its 2021 Forms 1094-C and 1095-C, the Transmittal of Employer-Provided Health Insurance Officer and Coverage Information Returns and the Employer-Provided Health Insurance Offer and Coverage respectively. The only notable changes to the 1094-C were the update of the year to 2021. There were several grammatical updates to the 1095-C along with the form being updated for Tax Year 2021. Other updates include the addition of two new codes. The most notable updates to the 1095-C are detailed below.
• New Code in use – Code 1T now designated “Individual coverage HRA offered to employee and spouse (no dependents) with affordability determined using employee’s primary residence ZIP code.”
• New Code in use – Code 1U now designated “Individual coverage HRA offered to employee and spouse (no dependents) using employee’s primary employment site ZIP code affordability safe harbor.”
• Line 15 instructions – Added mention of codes 1T and 1U regarding when line 15 will show an amount
• Line 17 instructions – Added references for codes 1T and 1U for determining affordability of individual coverage HRA.
At this time, no changes have been noted to the instructions though the 2021 instructions have not been released in their final form at this time.
To view Form 1094-C, click here.
To view Form 1095-C, click here.

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Robert Beck

Robert Beck is a Junior Regulatory Counsel at Sovos Compliance. As part of the Regulatory Analysis team, his main areas of focus are state and federal tax withholding, and the Affordable Care Act (ACA). Robert is a member of the Massachusetts Bar and received his J.D. from New England Law | Boston and his B.A. in Justice from University of Alaska Fairbanks.
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