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IRS Extends the ACA's Form 1094 and Form 1095 Filing Deadlines

The IRS has unexpectedly extended the deadlines by which insurers and self-funded employers must provide health plan enrollment and coverage information to employees and the IRS under the Affordable Care Act. This is the information required to be reported on Forms 1094 and 1095. Notice 2016-4 issued December 28 extends the due dates:

  • For providing to full-time employees the 2015 Form 1095-B and the 2015 Form 1095-C from February 1, 2016 to March 31, 2016; and
  • For filing with the IRS the 2015 Form 1094-B, the 2015 Form 1095-B, the 2015 Form 1094-C, and the 2015 Form 1095-C from February 29, 2016 to May 31, 2016 (if not filing electronically), and from March 31, 2016 to June 30, 2016 (if filing electronically).

By issuing the extensions, the IRS has responded to requests from trade and industry associations to give insurers and self-funded employers more time in which to timely submit the required data to individuals and the government.

The IRS will not assess penalties if the employer makes a good faith effort to comply with the reporting requirements. Similarly, the Notice provides individuals who file tax returns before receiving a Form 1095-B or Form 1095-C will not be required to amend their returns after receiving the forms.

This table summarizes the reporting requirements in light of the extended due dates:

Fully Insured

< 50 Full-time Employees

Fully Insured

≥ 50 Full-time Employees

Self-Funded

< 50 Full-time Employees

Self-Funded

≥ 50 Full-time Employees

New Deadline

Forms to Employees

1095-B

1095-B/1095-C (Parts I and II only)

1095-B

1095-C (All parts)

3/31/2016

Submitted to Employees By

Insurer

Insurer/Employer

Employer

Employer

Forms to IRS

1094-B

1094-B (with copies of all 1095-Bs/1094-C (with copies of all 1095-Cs

1094-C (with copies of all 1095-Cs)

1094-C (with copies of all 1095-Cs)

5-31-2016

(if not filing electronically)

6/30/2016

(if filing electronically)

Filed with IRS By

Insurer

Insurer/Employer

Employer

Employer

For more information on ACA information reporting and compliance planning, please contact either Brent Gambill (937/449-5539; gambill@coollaw.com) or Edie Crump (937/449-5530; crump@coollaw.com).

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