IRS Extends Affordable Care Act Information Reporting Deadlines
In Notice 2016-4 (the “Notice”) issued by the Internal Revenue Service (“IRS”) on December 28, 2015, the IRS extended due dates for the 2015 information reporting forms required to be filed and furnished under the Affordable Care Act (the “ACA”).
Pursuant to the Notice:
- The due date for furnishing the 2015 Form 1095-B, Health Coverage, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, to individuals has been extended from February 1, 2016, to March 31, 2016; and
- The due date for filing the 2015 Form 1094-B, Transmittal of Health Coverage Information Returns, the 2015 Form 1095-B, Health Coverage, the 2015 Form, 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, with the IRS has been extended from February 29, 2016, to May 31, 2016, if not filing electronically, and from March 31, 2016, to June 30, 2016, if filing electronically.
The Notice further provides that despite the extended due dates for furnishing and filing the required ACA reporting forms, the IRS is nonetheless prepared to accept filings of the information returns beginning as early as January 2016. The Notice also encourages employers and other entities required to furnish and file the required ACA reporting forms to furnish the statements to individuals and to file the information returns with the IRS as soon as they are ready to be furnished and/or filed, as applicable, notwithstanding the extended due dates.
Finally, the Notice reiterates the IRS’s position that certain applicable filing penalties will not be imposed on reporting entities that reported incorrect or incomplete information on their 2015 forms, provided the entity can show that they have made good faith efforts to comply with the ACA information reporting requirements.