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Focus on Healthcare: Affordable Care Act Reporting Deadline Extension for Forms 1094 and 1095

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The U.S. Treasury and Internal Revenue Service recently extended the 2015 Affordable Care Act (ACA) information reporting deadlines to give employers and payroll service providers more time to fulfill these requirements.
January 14, 2016

The U.S. Treasury and Internal Revenue Service recently extended the 2015 Affordable Care Act (ACA) information reporting deadlines to give employers and payroll service providers more time to fulfill these requirements.

For 2015, Form 1095-B and Form 1094-B will be filed by insurance companies, employers who use the SHOP Exchange, small self-funded groups and individuals who get coverage outside of the health insurance marketplace. Form 1095-C and Form 1094-C will be filed by applicable large employers. It is also important to note that small employers (an employer that has fewer than 50 full-time employees) are also required to file form 1095-C and 1094-C if they are a part of an aggregate or controlled group or if they are self-funded.

Originally, Form 1095 was to be due annually to each applicable employee by January 31, and Form 1094 was to be due annually by February 28 (or March 31 if filed electronically). However, with the recent release of IRS Notice 2016-4, these deadlines have been extended and employers now have until March 31, 2016 to furnish the 2015 Form 1095-B and 1095-C to employees. The due date to file 2015 Forms 1094-B, 1095-B, 1094-C and 1095-C with the IRS has been extended to May 31, 2016 (or June 30, 2016 if filing electronically). These changed deadlines only apply for 2015 forms filed in 2016.

Since Notice 2016-4 extended the information reporting deadlines, the normal provisions for requesting an extension, beyond the deadlines established by this notice, will not apply. While the IRS could assess penalties for late filing of the 2015 ACA forms, the agency is still encouraging employers to file the forms even if they are unable to meet the extended deadline. The IRS will consider “reasonable cause” when determining whether to reduce or abate penalties. Additionally, the IRS will also take into account whether the employer has taken adequate measures to prepare for the 2016 ACA forms when determining whether to reduce or abate penalties for failing to timely file the 2015 ACA forms.

Moreover, the extended due dates for the information returns may make it difficult for employees to receive their information in time to file their individual returns. The IRS is providing relief to these individuals and will not require an amended return to be filed if an individual receives their statements after they have filed their return. That being said, individuals do not have to wait for their Form 1095-B or 1095-C in order to file their 2015 return. However, it is still important to retain these statements for tax records.

View or download Form 1095-C.

View or download Form 1094-C.

 

Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.

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