A Little Breathing Room: IRS Extends ACA Reporting Deadline and Good Faith Penalty Relief

The IRS delivered welcome news to employers gearing up to meet the Affordable Care Act’s (“ACA”) information reporting deadlines for the 2016 calendar year. In Notice 2016-70, the IRS extended the deadline to furnish Forms 1095-B and 1095-C to employees.  The new deadlines are provided below.

  Old Distribution Deadline New Distribution Deadline
Form 1095-B (to employees) January 31, 2017 March 2, 2017
Form 1095-C (to employees) January 31, 2017 March 2, 2017

Importantly, the Notice does not extend the deadline for filing Forms with the IRS.  The deadline to file with the IRS remains February 28, 2016 (for paper filings) and March 31, 2017 (for electronic filings). Read More ›

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IRS Delivers Belated Christmas Gift – Extends ACA Reporting Deadlines

The IRS delivered a late Christmas gift December 28, 2015 when, in Notice 2016-4, it extended the Affordable Care Act (“ACA”) reporting deadlines.  The new deadlines affect distribution and filing of Forms 1094 and 1095 for calendar year 2015 and are provided below.

Section 6055
Health Coverage Reporting
Old Filing Deadline New Filing Deadline
Form 1095-B (to employees) February 1, 2016* March 31, 2016
Form 1094-B (to IRS) February 29, 2016 (paper filing)
March 31, 2016 (electronic filing)
May 31, 2016 (paper filing)
June 30, 2016 (electronic filing)
Section 6056
Employer-Provided Health Insurance Offer and Coverage Reporting
Old Filing Deadline New Filing Deadline
Form 1095-C (to employees) February 1, 2016* March 31, 2016
Form 1094-C (to IRS) February 29, 2016 (paper filing)
March 31, 2016 (electronic filing)
May 31, 2016 (paper filing)
June 30, 2016 (electronic filing)

In light of this transitional relief, the IRS will not accept automatic or permissive extensions for filing Forms 1094 and 1095. Read More ›

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Final Forms and Instructions for ACA Information Reporting Released

The IRS recently released the final forms and instructions for information reporting under the Affordable Care Act (“ACA”).  The final forms and instructions will be used for reporting in 2016 concerning 2015 coverage.  The final forms and instructions can be accessed below.

Form 1094-B

Form 1095-B

Instructions for Forms 1094-B and 1095-B

Form 1094-C

Form 1095-C

Instructions for Forms 1094-C and 1095-C

The final forms do not contain any significant changes from the prior draft versions.  Both sets of final instructions also remain largely unchanged, but they contain a few important modifications with respect to reporting specific types of coverage.  For example, the final instructions modified the rules for reporting multiemployer plan coverage, COBRA coverage, and HRA coverage. Read More ›

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