Employment Law Report
ACA Reporting Deadline Extended
The IRS recently released good news for employers, service providers, and others who are required to file the 1094 and 1095 series Information Return forms pursuant to the Affordable Care Act. In Notice 2016-4, the IRS has granted additional time for filing these forms for 2015:
- The deadline for providing individuals with Form 1095-B (Health Coverage) and Form 1095-C (Employer-Provided Health Insurance Offer and Coverage) has been extended from February 1, 2016, to March 31, 2016; and
- The deadline for filing Form 1094-B (Transmittal of Health Coverage Information Returns), Form 1095-B (Health Coverage), Form 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns), and Form 1095-C (Employer-Provided Health Insurance Offer and Coverage) has been extended from March 31, 2016, to June 30, 2016 if filing electronically, and from February 29, 2016 to May 31, 2016, if not filing electronically.
Employers and service providers should not, however, expect any further extensions. As the IRS explained: “In view of these extensions, the provisions regarding automatic and permissive extensions of time for filing information returns and permissive extensions of time for furnishing statements will not apply to the extended due dates. Employers or other coverage providers that do not comply with these extended due dates are subject to penalties under section 6722 or 6721 for failure to timely furnish and file. However, employers and other coverage providers that do not meet the extended due dates are still encouraged to furnish and file, and the Service will take such furnishing and filing into consideration when determining whether to abate penalties for reasonable cause . . . .”