Just in time to celebrate the New Year, the IRS released Notice 2016-4 which announced the extension of due dates for Affordable Care Act (ACA) reporting. If you’re not familiar with the ACA reporting requirements, we refer you back to our October blog post which can be found here. By delaying the deadlines, the IRS is allowing employers and insurers more time to gather required information and adapt their business practices to allow for use of the forms.
In short, if your business is required to comply with the ACA mandate of offering health coverage to 100% of your full time employees and their dependents (until age 26), you must report this information on IRS forms 1094-C and 1095-C in 2016. The due dates for these forms have been extended as follows:
- The due date for furnishing the 2015 Form 1095-C to the insured and employees is extended from February 1, 2016, to March 31, 2016.
- The due date for health coverage providers and employers furnishing the 2015 Form 1094-C to the IRS is extended from February 29, 2016, to May 31, 2016 if not filing electronically.
- The due date for health coverage providers and employers electronically filing the 2015 Form 1094-C with the IRS is extended from March 31, 2016, to June 30, 2016.
It is important to note that due to the extension, some employees will not receive their forms until after the April 15 tax filing deadline. The IRS indicates that these employees do not have to file an amended tax return. They should, however, keep their forms readily available in case they need them later.
No official extension request is required and there is nothing you need to do to take advantage of the extended due dates. Despite the extension, the IRS is encouraging employers and other coverage providers to provide statements and file the forms as soon as they are ready. The IRS is prepared to accept information reporting returns beginning this month.
Happy New Year!