Issue 97: Another Holiday Gift - ACA Reporting Deadlines Extended!

This is the ninety-seventh issue in our health care reform series of alerts for employers on selected topics in health care reform. (Our general summary of health care reform and other issues in this series can be accessed by clicking here.) This series of Health Care Reform Management Alerts is designed to provide a more in-depth analysis of certain aspects of health care reform and how it will impact your employer-sponsored plans.

On December 28th, the IRS issued Notice 2016-4 extending the 2015 filing deadlines for information reporting under Internal Revenue Code Sections 6055 and 6056. Notice 2016-4 provides an automatic extension for the filing deadlines, so no requests for extensions are necessary. The filing deadlines are extended as follows:

IRS Form	Prior 2015 Deadline	New 2015 Deadline with Transitional Relief
Forms 1095-B and 1095-C to insured and/or employees	February 1, 2016	March 31, 2016
Forms 1094-B and 1094-C to IRS	February 29, 2016	May 31, 2016
Forms 1094-B and 1094-C filing electronically to IRS	March 31, 2016	June 30, 2016

Notice 2016-4 states that the IRS delayed the filing deadlines for employers, insurers and other health plan coverage providers after it determined that providers needed “additional time to adapt and implement systems to gather, analyze and report this information.” However, the Notice also states that the IRS is encouraging providers to furnish statements and file the information returns as soon as they are ready.

Finally, the Notice provides guidance to individuals who might not receive a Form 1095-B or Form 1095-C by the time they file their 2015 tax returns. Individuals who rely upon other information received from their employer when filing their income tax returns need not amend their returns once they receive their Forms 1095-C or any corrected Forms 1095-C. Individuals need not send this information to the IRS when filing their returns but should keep it with their tax records.