While the deadline to electronically file Affordable Care Act (ACA) information returns with the IRS passed on June 30, 2016, the ACA Information Returns (AIR) system used to electronically file those returns will remain up and running.
On June 30th, the IRS noted the following on its AIR system home page:
- The AIR system will continue to accept information returns filed after June 30, 2016. In addition, employers can still complete required system testing after June 30, 2016.
- When a filing is “accepted with errors,” the employer has 60 days to submit a replacement before penalties accrue any further. For example, employers who filed their 1094-C by June 30th and who submit a replacement within 60 days of June 30th will have the submission treated as timely filed.
- Employers that were unable to submit their returns by June 30th should still file their returns after the deadline. Filers that missed the June 30, 2016 deadline will generally not be assessed late filing penalties if the employer made legitimate efforts to register with the AIR system and to file its information returns, and it continues to make such efforts and completes the process as soon as possible.
Additionally, while there is no specific relief provided in the case of employers that fail to file returns by the deadline, relief may be available if the IRS determines that there was reasonable cause for the delay.
Employers that did not file electronically and that missed the May 31, 2016, paper filing deadline should also complete the filing of their paper returns as soon as possible.
Stacy Barrow
Stacy Barrow advises UBF clients on various topics around ERISA and the ACA. One of the nation’s leading experts on the Affordable Care Act, Stacy uses a practical, business-focused approach to counsel his clients on all matters related to employee benefit plans. Stacy also has extensive technical knowledge and experience designing and implementing health and welfare plans that meet the numerous and intricate requirements of applicable federal and state law.
Stacy Barrow advises UBF clients on various topics around ERISA and the ACA. One of the nation’s leading experts on the Affordable Care Act, Stacy uses a practical, business-focused approach to counsel his clients on all matters related to employee benefit plans. Stacy also has extensive technical knowledge and experience designing and implementing health and welfare plans that meet the numerous and intricate requirements of applicable federal and state law.
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