IRS Publishes Tax Year 2019 ACA Business Rules

Tom Hospod
September 9, 2019

The IRS has released the business rules and specifications for electronic reporting of tax year 2019 healthcare coverage information in 2020. As a reminder, although the individual mandate penalty was zeroed out, the employer mandate and its reporting obligations and penalties remain in effect.

There are no changes to the Form-to-Schema Crosswalks; however, there are a few relevant changes to the business rules:

  • For 1094-B, 1094-C, and Shared Rules, business rules relating to Testing Scenarios were changed.
  • New rule for the Manifest Header when there is a foreign address. The Manifest Header contains transmitter’s address information.
  • The wording of the Form 1095-B business rules changed but they remain essentially the same.
  • Two new Form 1095-C business rules that replace previous ones with new reporting logic. Further information will be available once the 2019 form instructions are released.

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Tom Hospod

Tom Hospod is a Regulatory Counsel at Sovos Compliance. Within Sovos’ Regulatory Analysis function, Tom focuses om Affordable Care Act (ACA) reporting, Tax Withholding, and Automatic Exchange of Information (AEOI). Prior to Sovos, Tom worked as a legislative aide in the Massachusetts House of Representatives. Tom is a member of the Massachusetts Bar, earned his B.A. from Boston College and his J.D. from the University of Miami.
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