IRS Extends Deadlines for 1095-C Furnishing and Reporting!

Published by John Dalmata on December 30, 2015

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3 minute read

Just when you thought you’d unwrapped all of your presents, it looks like Santa had one more gift for employers hidden behind the desk in the corner of the family room.

And nobody can shoot their eye out with this one…

It was about a week before Christmas that we began hearing some “scuttlebutt” from our legal sources that a delay for Affordable Care Act Reporting was forthcoming, and if so, would be issued sometime between Christmas and New Year’s.

That official notice came on Monday, December 28. The IRS issued Notice 2016-4, extending the reporting deadlines for issuing individual 1095-C returns to employees, and filing 1095-B & 1094-B and 1095-C & 1094-C returns with the IRS. Verbatim, the notice reads:

Specifically, this notice extends the due date (1) for furnishing to individuals the 2015 Form 1095-B, Health Coverage, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from February 1, 2016, to March 31, 2016, and (2) for filing with the Service the 2015 Form 1094-B, Transmittal of Health Coverage Information Returns, the 2015 Form 1095-B, Health Coverage, the 2015 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from February 29, 2016, to May 31, 2016, if not filing electronically, and from March 31, 2016, to June 30, 2016 if filing electronically.

The notice goes on to explain that the IRS is still prepared to receive forms and transmittals come January of 2016. It further states the reason for the delay was that “the Department of the Treasury (Treasury) and the Service have determined that some employers, insurers, and other providers of minimum essential coverage need additional time to adapt and implement systems and procedures to gather, analyze, and report this information.”

The IRS made no comment on whether or not their own level of readiness had anything to do with the delay. Frankly, who cares—we’re not about to look a gift-horse in the mouth.

The IRS also encourages employers to file early, and not use the extension for further procrastination. By all means, take a moment to finish your eggnog (Benetech Director of Ops, John Dalmata, made this eggnog recipe this year. Amazing!) and watch a few bowl games before diving back into your 1095-Cs. At Benetech, we’ll continue to publish the content and provide the help you need to get through your first year of reporting. We’re all in this together.

Learn more about Benetech’s ACA Reporting Solution, ACAtrac©

Furthermore, automatic and permissive extensions that had previously been issued, in light of the extensions included within this notice, will not apply to the extended due dates. Prior to this notice, the IRS had permitted employers to petition for a 30-day extension to filing their annual 1094/1095 forms.

So, to sum it up, the new reporting deadlines are as follows:

March 31: Issue forms 1095-C to employees
May 31: Employer 1094/1095-C & 1094/1095-B Deadline for IRS paper filing
June 30: Employer 1094/1095-C & 1094/1095-B Deadline for IRS electronic filing