Are the 1095-C Forms for Reporting Health Coverage in the Year 2022 a Requirement in 2023?
Question: Are the 1095-C forms for reporting health coverage in the year 2021 a requirement in 2022?
Answer: Yes, Applicable Large Employers are required to comply with the existing reporting requirements for the 2022 tax year reporting by the deadlines in 2023. Given that the individual mandate penalty is zero for the 2020 tax year and on, there is an argument for the Part III reporting on form 1095-C to be eliminated. The industry will have to wait for guidance on this from the IRS on tax year 2022 reporting. It’s our opinion that because the individual mandate remains (albeit with no penalty), the reporting will remain as well. It’s a given that Part II (employer mandate) reporting will remain for the 2022 tax year and beyond.
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