Employers Get Relief as IRS Extends Due Dates for 2015 ACA Reporting

On December 28, 2015, the IRS released Notice 2016-4 to extend due dates for the 2015 information reporting required by the Affordable Care Act (ACA). Employers will have an additional two months to furnish forms to individuals and an extra three months to file forms with the IRS.

Applicable large employers (ALEs), who generally are entities that employed 50 or more full-time and full-time-equivalent employees in 2014, are required to report information about the health coverage they offered or did not offer to certain employees in 2015. To meet this reporting requirement, the ALE will furnish Form 1095-C to the employee or former employee and file copies, along with transmittal Form 1094-C, with the IRS.

Employers, regardless of size, that sponsored a self-funded (self-insured) health plan providing minimum essential coverage in 2015 are required to report coverage information about enrollees. To meet this reporting requirement, the employer will furnish Form 1095-B to the primary enrollee and file copies, along with transmittal Form 1094-B, with the IRS. Self-funded employers who also are ALEs may use Forms 1095-C and 1094-C in lieu of Forms 1095-B and 1094-B.

Extended Due Dates:

Specifically, Notice 2016-4 extends the following due dates:

  • The deadline for furnishing 2015 Form 1095-C, or Form 1095-B, if applicable, to employees and individuals is March 31, 2016 (extended from February 1, 2016)
  • The deadline for filing the 2015 Forms 1095-C along with transmittal Form 1094-C, or Forms 1095-B with transmittal Form 1094-B, if applicable, with the IRS is:
    • If filing by paper, May 31, 2016 (extended from February 29, 2016)
    • If filing electronically, June 30, 2016 (extended from March 31, 2016)

The IRS previously provided a process for reporting entities to request extensions and some employers have already submitted their requests. Notice 2016-4 explains that the new extended due dates apply automatically (and are more generous than the prior process) so individual requests will not be granted formally.

Notice 2016-4 also provides guidance to taxpayers who do not receive a Form 1095-B or 1095-C by the time they file their 2015 individual tax return.

Health insurers have reporting requirements, too, and those due dates also are extended.

Lastly, the IRS encourages employers, insurers, and other reporting entities to furnish forms to individuals and file reports with the IRS as soon as they are ready.