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Compliance Corner: ACA Reporting Deadlines EXTENDED for 2015


Great news!  The IRS extended the deadlines for IRC Sections 6055 and 6056 ACA reporting of health coverage and full-time employment status.  Per Notice 2016-4, the extended deadlines are as follows:

  • March 31, 2016 -- Forms 1095-B and 1095-C to Individuals
  • May 31, 2016 (if not filing electronically) and June 30, 2016 (electronic filing) -- Forms 1095-B, 1095-C, 1094-B and 1094-C to IRS

Other notables in the Notice include the following:

  • These extensions apply automatically to all filers.  Therefore, employers and other reporting entities do NOT need to submit a request for these extensions.
  • The previously provided automatic and permissive extensions will not apply to further expand these newly extended deadlines.
  • These extensions are only applicable for Forms (information returns and statements) for calendar year 2015 filed and furnished in 2016.
  • Sections 6721 and 6722 penalties may apply for employers and coverage providers who do not meet these new deadlines.  (Note: Penalty for failing to provide information is $250+ per return/form for each failure.)
  • The IRS is prepared to accept filings beginning in January 2016 for anyone who is prepared to send sooner.
  • Employees and other individuals may be affected by the extension in regards to (1) eligibility for premium tax credit (subsidy) for Exchange/Marketplace coverage, and (2) proof of minimum essential coverage under the individual mandate.  An individual, who files his/her tax return prior to receipt of these forms does not need to amend the tax return upon receipt of the forms or send the forms to the IRS, if he/she relies on other information about his/her offer of health coverage from the employer and coverage information from the coverage provider.  However, the individual should retain the forms for his/her records.

Read Notice 2016-4 for official guidance