ACA Employer Reporting: Deadline Extensions

Dec 16, 2016

Distribution Deadline Extended

Great news! The IRS announced a deadline extension for providing 2016 Forms 1095-B and 1095-C to covered individual and full-time employees. The deadlines in which employers and carriers are required to file 2016 forms with the IRS have not been extended.

Deadlines

1095-C Form Distribution (to insureds and F-T employees): March 2, 2017
1095-B Form Distribution (to insureds): March 2, 2017
IRS Paper Form Filling: February 28, 2017
IRS Electronic Form Filing: March 31, 2017

Form Usage

1095-C Form: Issued by employers with 50 or more full-time employees (including full-time equivalents). The form is distributed to those insured by the employer sponsored plan and to full-time employees. It is used to determine an employee's eligibility for a premium tax credit and to demonstrate an employer's compliance with the employer mandate (Pay or Play).
1095-B Form: Issued by the carrier to fully-insured members. This form is used to help members verify on their tax return that they and their dependents had minimum essential coverage. The form does not need to be filed with a tax return, but it should be saved with tax documents. An insured may receive more than one 1095-B form if they were insured by more than one medical carrier during the 2016 calendar year.

Good Faith Reporting Relief Extended

The IRS has also extended the good faith penalty relief for employers required to report under sections 6055 and 6056 of the Internal Revenue Code.

The Internal Revenue Code imposes penalties for failing to file and furnish an accurate and complete information return, including Forms 1094 and 1095.
However, the IRS is extending penalty relief to reporting entities that can show they made a good faith effort to comply with the 2016 calendar year information reporting requirements.
The relief applies to missing and inaccurate taxpayer identification numbers and dates of birth, as well as other information required on the return or statement.
To determine good faith, the IRS considers whether an employer made reasonable efforts to prepare for reporting the required information to the IRS and furnishing it to employees and covered individuals, such as gathering and transmitting the necessary data to an agent to prepare the data for submission to the IRS, or testing its ability to transmit information to the IRS.
In addition, the IRS will consider the extent to which the employer is taking steps to ensure that it will be able to comply with the reporting requirements for the 2017 calendar year.

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