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December 16, 2021

IRS releases final Instructions for 2021 ACA reporting forms with new filing deadline, ICHRA provisions

On December 9, 2021, the IRS issued final instructions for Affordable Care Act (ACA) reporting Forms 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and 1095-C, Employer-Provided Health Insurance Offer and Coverage, for tax year 2021. The final instructions include the furnishing extension until March 2, 2022, which was announced in November as part of proposed regulations (see Tax Alert 2021-2165).

The only other change from 2020 is the addition of two individual coverage health reimbursement arrangement (ICHRA) codes for Line 14 of Form 1095-C. Beginning in 2020, employers could offer employees ICHRAs, which could, for the first time, reimburse employees for the cost of obtaining individual medical coverage or Medicare (employers offering ICHRAs may not also offer participation in a traditional group health plan).

The Form 1094-C remains unchanged from prior years.


Aside from the date extension, these final instructions are the same as the draft instructions issued earlier this fall.


Contact Information
For additional information concerning this Alert, please contact:
Workforce Tax Services/Affordable Care Act
   • Lori Maite (
   • Rebecca Truelove (
   • Ron Krupa (
   • Belinda A. Sharp (