IRS delays ACA information reporting deadlines

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In order to give employers and other insurance providers additional time to meet new Affordable Care Act (ACA) information reporting requirements, the IRS has extended the due date to report health care coverage information to employees and the IRS.
These new reporting requirements became effective for the 2015 calendar year. Applicable large employers (employers with 50 or more full-time and full-time equivalent employees) will use Form 1095-C to report health coverage information to employees and Form 1094-C to transmit information to the IRS. Other health insurance providers will use Form 1095-B to report information to insured individuals and Form 1094-B to transmit information to the IRS.  More information about these filing requirements from Grant Thornton is available.

Forms 1095-C and 1095-B are generally due to employees and insured individuals by Jan. 31 of each year. In Notice 2016-4, the IRS extended the due date for furnishing the 2015 Forms 1095-C and 1095-B from Feb. 1, 2016 (Jan. 31, 2016 falls on a Sunday) to March 31, 2016.

Notice 2016-4 also extends the due date for filing with the IRS the 2015 Forms 1094-B and 1094-C from February 29, 2016, to May 31, 2016, if not filed electronically, and from March 31, 2016, to June 30, 2016, if filed electronically.

No additional extension for 2015 Employers and insurance providers are generally able to request an extension of time to furnish statements to employees and insured individuals, and there are additional provisions regarding automatic and permissive extensions of time for filing information returns with the IRS. In Notice, 2016-4, the IRS said that these generally available extensions do not apply for the 2015 information statements. No extension will be provided beyond the due dates established in Notice 2016-4.  
However, the IRS encourages employers and other insurance providers that do not meet the extended due dates to furnish and file the required forms, and the IRS will take into consideration the filer’s efforts when determining whether to abate penalties for reasonable cause. Notice 2016-4 lists additional factors the IRS will consider when determining whether to abate penalties for the 2015 forms.

Next steps These new reporting requirements are complex and require a substantial investment by employers. The amount of information needed to complete these forms is immense. Employers should not view these extended due dates as an opportunity to delay taking action to complete the forms. Instead, employers should take advantage of the additional time to ensure they properly complete the forms by the extended due dates and avoid potential penalties. Contact Grant Thornton if you would like to discuss these reporting requirements.
Contacts Eddie Adkins
Washington National Tax Office
+1 202 521 1565

Jeff Martin
Senior Manager
Washington National Tax Office
+1 202 521 1526

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