Legal Update: Draft Forms for 2024 ACA Reporting Released

The Internal Revenue Service (IRS) has released draft 2024 forms for reporting under Internal Revenue Code Sections 6055 and 6056. Draft instructions for these forms have not yet been released.

• The 2024 draft Forms 1094-B and 1095-B are draft versions of forms that will be used by providers of minimum essential coverage—including self-insured plan sponsors that are not applicable large employers (ALEs)—to report under Section 6055.
• The 2024 draft Forms 1094-C and 1095-C are draft versions of forms that will be used by ALEs to report under Section 6056 as well as for combined Section 6055 and 6056 reporting by ALEs that sponsor self-insured plans.

No major changes were made to the draft forms for 2024 reporting. However,certain changes may be made once the forms and instructions are finalized.

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