United States

IRS extends the filing dates for Affordable Care Act information returns

Employers have more time to file Forms 1095-B and 1095-C in 2016


On Dec. 28, 2015, the IRS announced in Notice 2016-4 an extension for filing 2015 information returns under the Affordable Care Act (ACA).

Due to the ACA, new Forms 1095-B (Health Coverage) and 1094-B (Transmittal of Health Coverage Information Returns) must be filed by insurance companies for 2015 to report individuals covered by insured employer-sponsored group health plans. Small employers with self-insured health plans file these forms to report employees and their family members who have coverage under the self-insured plan.

Every large employer (an employer with at least 50 full-time and full-time equivalent employees) must report information about its 2015 workforce and health plans to its employees and the IRS using Forms 1095-C (Employer-Provided Health Insurance Offer and Coverage) and 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns). The forms report whether the employer offered ACA-compliant health coverage to its employees. Electronic filing is required if the employer files at least 250 returns.

Originally the Forms 1095-B and 1095-C were to be provided to employees by Feb. 1, 2016, for use on their 2015 individual income tax returns. The notice extends that date to March 31, 2016. Furthermore, the IRS indicated that individuals filing their tax returns prior to receiving the forms will not be required to amend their returns if they relied on other information about their health plan coverage when preparing their returns.  

The due dates for filing the returns with the IRS have also been extended. Forms 1095-B and 1095-C, along with Forms 1094-B and 1094-C, were to be filed with the IRS by Feb. 29, 2016; however, the new due date is May 31, 2016, if filed on paper. If filed electronically, the original due date of March 31, 2016 is extended to June 30, 2016. These extensions of the filing due dates are automatic so insurers and employers do not need to submit an extension request with the IRS to take advantage of these delayed due dates.

Employers will be subject to penalties of up to $500 per return for failing to timely file the returns and furnish statements to employees. 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.

For more information on the ACA reporting requirements, please see this article.


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