"The draft 2020 Form 1095-C remains substantially similar to prior year's forms. However, employers sponsoring individual-coverage health reimbursement arrangements (HRAs) will want to take note of the eight new line 14 codes to accommodate employer-shared responsibility (ESR) and premium tax credit reporting of these HRAs.... [E]mployers with employees residing in California, Massachusetts, New Jersey, Rhode Island, Vermont and Washington, DC, may want to review the implications for reporting under the individual-coverage mandates in those jurisdictions."