The Internal Revenue Service (IRS) released the draft 2020 Forms 1094-C and 1095-C on July 13, 2020. While Form 1094-C remains the same, as expected, there are some changes to IRS Form 1095-C based on the introduction in 2020 of a new type of Health Reimbursement Account (HRA), the individual coverage HRA or ICHRA. Starting January 1, 2020, employers may offer employees an ICHRA instead of offering a traditional group health plan to reimburse medical expenses, like monthly premiums and out-of-pocket costs such as copayments and deductibles. An offer of an ICHRA counts as an offer of health coverage under the employer mandate of the Affordable Care Act (ACA), is subject to the ACA’s affordability and minimum value requirements, and also affects ACA information reporting. The IRS has not yet published draft 2020 Instructions for Forms 1094-C and 1095-C.