Affordable Care Act (ACA) Reporting Deadlines Extended

Here’s some good news from the IRS: After discussions with stakeholders, the Internal Revenue Service and the Department of the Treasury agreed that some employers, insurers, and others who provide minimum essential coverage needed more time to gather, analyze, and report information required for compliance with the Affordable Care Act (ACA). Responding to this need, they decided to extend deadlines for 2015 reporting.

On Monday, December 28, 2015, the IRS released Notice 2016-4, extending the due dates for 2015 information reporting under the IRS Code sections 6055 and 6056. This includes providing required forms to individuals as well as filing with the IRS.

Paper vs. electronic filing

The ACA compliance extension for furnishing individuals with 2015 Forms 1095-B and 1095-C moves the deadline from February 1, 2016 to March 31, 2016. If you file 2015 Forms 1094-B, 1095-B, 1094-C, and 1095-C with the IRS using paper forms, your deadline is moved from February 29, 2016 to May 31, 2016. You have more time if you file electronically. That deadline is moved from March 31, 2016 to June 30, 2016. 

The IRS will consider late forms

While the IRS encourages you to file as soon as you are able and states that those that do not comply with the new deadlines are liable for penalties, they will give consideration to those who do not meet the extended due dates. Making a reasonable effort to comply and showing that they are making preparations to comply when filing 2016 forms may affect the IRS response. However, Notice 2016-4 does not elaborate on how these efforts will affect penalties.

Effects on individual taxpayers

The IRS notice also addresses possible effects of the extensions on employees who find health insurance in the Marketplace. Their eligibility for the premium tax credit can change for any month they may be eligible for participation in an employer-sponsored plan. However, Notice 2016-4 concludes that most employees will not be affected.

Questions?

If, after reading the notice, you still have questions, call Michael Hara of the Office of Associate Chief Counsel (Procedure and Administration). He is the main author of this notice and can be reached at 202.317.6845 (not a toll-free call).