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IRS Extends Key Due Dates for 1095 Forms

Jan 4th 2016
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The IRS is giving employers and health coverage providers a little more time to meet 2015 information reporting requirements under the Affordable Care Act.

Notice 2016-4, which was issued by the IRS on Dec. 28, allows employers and insurers an extra two months to provide individuals with 2015 forms for reporting on offers of health coverage and coverage provided. This pertains to Form 1095-B, Health Coverage, and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage.

The original deadline was Feb. 1. The new deadline is March 31.

In addition, the deadlines for reporting this information to the IRS were extended by three months. The deadline for those filing paper returns was pushed back from Feb. 29 to May 31, and the deadline for those filing electronically was extended from March 31 to June 30.

Forms that must be filed with the IRS include Form 1094-B, Transmittal of Health Coverage Information Returns, Form 1095-B, Health Coverage, Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage.

This is the first year that employers and insurers are required to report certain information about health coverage under the Affordable Care Act to “employees, other individuals, and the IRS,” according to the US Treasury Department.

“The vast majority of individual taxpayers will not be affected by this extension,” the Treasury Department said in a Dec. 28 statement. â€œ Like last tax-filing season, most individuals will simply check a box on their tax return indicating they had health coverage for the entire year. These forms provide individuals with a record of their health coverage, but do not need to be attached to the tax return. This notice also provides guidance to the limited number of individuals who might be affected by the extension. In particular, individuals who file their tax returns relying on other information about their health care do not need to amend their returns. The additional time provided to employers and insurers will also not materially affect the IRS's ability to use the information provided to verify compliance.”

The IRS indicated it was prepared to accept Affordable Care Act reporting in January, but due to feedback from businesses and insurers, the agency decided to give employers extra time to complete the necessary forms for this first year. It also allows more time for businesses to implement systems and procedures in order to gather, analyze, and report information about the health coverage they offer and provide, the Treasury Department said.

Gretchen Young, senior vice president of health policy for the Washington, DC-based ERISA Industry Committee, which had pushed the IRS for a 60-day extension, said in a written statement, “I am thrilled that companies will receive this desperately needed relief from the very complicated and onerous filing and furnishing requirements. It is great that the government was so responsive to our urgent and continuing requests for a delay.”

Employers will be subject to penalties of up to $500 per return for failing to timely file the returns and furnish statements to employees, according to a Tax Alert from accounting firm RSM US LLP. Penalties also apply for failing to provide complete or correct returns. However, the IRS has indicated that it will not impose penalties for incorrect or incomplete returns for 2015 if the employer makes a good-faith effort to comply with the information reporting requirements and provides the forms to employees and the IRS on a timely basis.

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