Compliance Update: IRS Extends Deadlines for 2015 ACA Information Reporting Requirements

Employers will have two more months—until March 31—to give individuals 2015 forms for reporting on offers of health coverage and the coverage provided, the IRS said Dec. 28 in Notice 2016-4. These are the Form 1095-B, Health Coverage, and the Form 1095-C, Employer-Provided Health Insurance Offer and Coverage. The former deadline was Feb. 1.

The deadlines for reporting this information to the IRS are extended by three months. The deadlines are now May 31 for those not filing electronically, and June 30 for electronic filers—versus the previous Feb. 29 due date for paper filings, and March 31 deadline for electronic returns.

Reporting to the IRS is done through 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.

Transition Relief Provided for Employers and Other Coverage Providers

IRS Notice 2016-4 extends the due dates, both furnishing to individuals and filing with the IRS, for the 2015 ACA information reporting requirements that apply to self-insuring employers (and other providers of minimum essential coverage) and applicable large employers under sections 6055 and 6056 of the Internal Revenue Code.

2015 Deadline Extension
Specifically, the notice extends the due date:

• For furnishing to individuals the 2015 Forms 1095-B and 1095-C, from February 1, 2016, to March 31, 2016, and
• For filing with the IRS the 2015 Forms 1094-B, 1095-B, 1094-C, and 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).

As a reminder, Forms 1094-B and 1095-B (available in our Members Section)  will be used by self-insuring employers that are not considered applicable large employers, and other parties that provide minimum essential health coverageaw, to report information on this coverage to the IRS and to covered individuals. Applicable large employers—generally those with 50 or more full-time employees, including full-time equivalents or FTEs—will use Forms 1094-C and 1095-C (please log in to see these forms) to report information to the IRS and to their employees about their compliance with “pay or play” and the health care coverage they have offered.

For more information about the definition of the full time employee, please click here.

Note: Employers subject to both reporting provisions (generally self-insured employers with 50 or more full-time employees, including FTEs) will satisfy their reporting obligations using Forms 1094-C and 1095-C. Form 1095-C includes separate sections for reporting under each provision.

Extension Applies for 2015 Calendar Year Only
The extensions for the ACA information reporting requirements apply for calendar year 2015 only and have no effect on the requirements for other years or on the effective dates or application of the ACA “pay or play” provisions. In view of these extensions, the IRS rules 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 will be subject to penalties.

In light of the continued changes to the ACA, we are committed to providing you the most up to date news and information about legislation impacting your business. Please check our blog regularly for more updates and contact us to learn more about our fully compliant employee benefit programs. Since 1929 NARFA has provided best in class service, administrative support, and much more to our members.