Health Care

IRS Extends Due Dates for ACA Information Reporting

Jan 15, 2016

On Dec. 28, 2015, the Internal Revenue Service (IRS) issued Notice 2016-4, which extends the due dates for employers subject to the Affordable Care Act’s (ACA’s) 2015 information reporting requirements.

Specifically, this notice gives employers additional time to provide employees with certain forms that they will be required to file with the IRS. Some of the ACA reporting requirements are applicable to large employers (those with 50 or more full-time employees, including full-time equivalents) and are designed to show compliance with the shared-responsibility employer mandate, while other reporting requirements apply to all employers that provide minimum, essential health coverage. Under the ACA, applicable employers are required to distribute a new health care disclosure form to their employees by Feb. 1, 2016. American employees must submit their health care disclosure form along with their Form W-2 when filing their income tax returns, which must be done by April 18, the IRS tax filing deadline in 2016. (In 2016, the tax deadline is Monday, April 18, since Emancipation Day, a federal holiday for most government workers including the IRS, will be celebrated on April 15.)

In Notice 2016-4, the IRS extended the following due dates:

Notice to employees — For furnishing employees with the 2015 Form 1095-B (Health Coverage) and Form 1095-C (Employer-Provided Health Insurance Offer and Coverage), the deadline is extended from Feb. 1, 2016, to March 31, 2016.

Employer filing with the IRS — For filing with the IRS the 2015 Form 1094-B (Transmittal of Health Coverage Information Returns), Form 1095-B, Form 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns) and Form 1095-C, the deadline is extended from Feb. 29, 2016, to May 31, 2016, if not filing electronically and from March 31, 2016, to June 30, 2016, if filing electronically. Any employer filing 250 or more forms must do so electronically.

The notice also provides guidance to those who might not receive a Form 1095-B or Form 1095-C by the time they file their 2015 tax returns. For additional information and guidance on the ACA reporting requirements, please click HERE.

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