In a welcome development for employers and health coverage providers, the IRS has extended the Affordable Care Act information reporting deadlines. Unlike the prior transition relief in which the IRS delayed the information reporting requirements for a full year to 2015, under the new guidance, the IRS only extends the reporting deadlines by a few additional months for coverage offered or provided during the 2015 calendar year.
Accordingly, certain reporting entities including employers and multiemployer plans have an additional two months to provide individuals with a 2015 Form 1095-B, which provides details on whether an individual is enrolled in minimum essential coverage. Employer sponsors of health coverage (including those with self-insured coverage) also have an additional two months to provide individuals with a 2015 Form 1095-C information statement, which, among other things, allows the IRS to determine whether an employer has offered employees coverage in compliance with the employer mandate. Reporting entities have an additional three months to submit these same statements to the IRS using the applicable Form 1094-B and 1094-C transmittal statements.
Below is a summary of the new deadlines:
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Report
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Initial Deadline
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New Deadline
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1094-B (transmittal to IRS)
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February 29, 2016 (mail)
March 31, 2016 (electronic)
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May 31, 2016 (mail)
June 30, 2016 (electronic)
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1094-C (transmittal to IRS)
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February 29, 2016 (mail)
March 31, 2016 (electronic)
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May 31, 2016 (mail)
June 30, 2016 (electronic)
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1095-B (information statement to employees and covered individuals)
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February 1, 2016
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March 31, 2016
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1095-C (information statement to employees and covered individuals)
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February 1, 2016
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March 31, 2016
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The IRS has made it clear that it is prepared to accept information statements by the original deadlines. And, for 2015 reporting, the IRS will not penalize a reporting entity that supplies incomplete or erroneous information in the reports, provided the reporting entity makes a good faith attempt to comply with the reporting requirements.
In addition, the IRS will no longer be responding to specific requests from reporting entities for more time to report, because this extension is more generous than the specific extensions that it has granted to date. While reporting entities now have more time to complete and furnish information reports, it is important that smaller employers in particular continue to take steps to develop internal systems or coordinate with vendors to be able to complete this new reporting obligation in the coming months.
