Good news for time-pressed employers struggling to comply with the complex reporting and implementation requirements: The Internal Revenue Service recently granted employers an extension of the deadline to file a variety of reports required under the Affordable Care Act (ACA).
The new deadline grants applicable large employers (ALEs), health insurers, and any employers who self-insure their employee medical insurance plans an additional two months to get their information together and forward the applicable ACA forms to the Internal Revenue Service.
The deadline extension may also benefit other providers of minimum essential coverage, if they are among those required to provide workers with information and to file informational reports with the IRS in accordance with Code Section 6055.
What Forms Are Affected?
The new reporting requirements, spelled out in IRS Notice 6014-4, affect those required to file Forms 1094-B, 1094-C, 1095 B and/or 1095-C.
The new deadlines are as follows:
Form 1095-Cs, originally due to individuals by February 1, 2016, are now due on March 31.
Paper filers
- Paper Form 1094-C, originally due to the IRS on February 29, 2016, is now due on May 31, 2016. This deadline applies only to those filing this form on paper, rather than electronically.
- Paper Form 1095-C, originally due to the IRS on February 29, 2016, is now due on May 31, 2016. Again, this deadline applies only to those filing on paper, rather than electronically.
Electronic filers
If you are filing your ACA reporting forms electronically, rather than on paper, the following deadlines apply:
- Form 1094-C, originally due to the IRS on March 31, 2016, is now due on June 30, 2016.
- Form 1095-C, originally due to the IRS on March 31, 2016, is now due to the IRS on June 30, 2016.
B-Form Deadlines Also Extended
The IRS also extended the due dates for Form 1095-B, Health Coverage, from February 1, 2016 to March 31, 2016.
The deadline for Form 1094-B, Transmittal of Health Coverage Information Returns, is extended from March 31 to May 31, 2016, if you file on paper. If you file electronically, the deadline has been moved from March 31, 2016 to June 1, 2016.
Additional Directives
The IRS notice reiterates that penalties will still apply to employers with obligations under the Affordable Care Act to report health information to employers and the IRS. While the deadlines have been extended, the penalties for untimely filing or for not filing the form at all can be significant. These penalties are spelled out in Code Sections 6722 and 6721. However, if you have trouble meeting the deadlines above, the IRS encourages you to file as soon as you can. The Notice indicates that the IRS will consider the fact that you furnished and filed as mitigating factors in assessing any penalties. The IRS also states that it will consider whether you made reasonable efforts to prepare for the filing and furnishing requirements, as well as any steps you take to ensure compliance with the deadline and other filing requirements in the future.
If you have employees who will not receive a Form 1095-C to file their own individual income taxes by the deadline, the IRS also provides some guidance for them in the notice, too.
Alan Wang is the President of UBF and serves as the lead consultant. He has delivered the UBF solution set throughout the world and is highly regarded for his areas of expertise. You can follow him on Twitter @UBFconsulting.