ACA Reporting Deadlines Delayed

Dec 29, 2015

ACA REPORTING DEADLINES DELAYED

OVERVIEW

On Dec. 28, 2015, the Internal Revenue Service (IRS) issued Notice 2016-4 to delay the due dates for filing and furnishing forms under Section 6055 and 6056.

ACTION STEPS

The IRS is encouraging employers and other coverage providers to furnish statements and file information returns as soon as they are ready.

The new deadlines are more generous than prior extensions and apply automatically to all reporting entities. No request or additional documentation is required. Entities that had previously requested extensions will not be receiving formal approval of those requests.

 Section 6055 and 6056 Reporting

Section 6055 and Section 6056 were added to the Internal Revenue Code (Code) by the Affordable Care Act (ACA).

 Section 6055 applies to providers of minimum essential coverage, such as health insurance issuers and employers with self-insured health plans. These entities will generally use Forms 1094-B and 1095-B to report information about coverage they provided during the previous year. 

Section 6056 applies to applicable large employers (ALEs)­­—generally, those employers with 50 or more full-time employees, including full-time equivalents, in the previous year. ALEs will use Forms 1094-C and 1095-C to report information relating to the health coverage that they offer (or do not offer) to their full-time employees.

 Notice 2016-4 Transition Relief

 The IRS is prepared to accept filings of the required forms beginning in January 2016. However, the IRS has determined that some employers, insurers and other providers of minimum essential coverage need additional time to adapt and to implement systems and procedures to gather, analyze and report this information.

 Therefore, Notice 2016-4 extends the due dates for Section 6055 and 6056 reporting. Specifically, the notice extends the due dates for: 

     Furnishing the 2015 Forms 1095-B and 1095-C to individuals, from Feb. 1, 2016, to March 31, 2016; and 

     Filing the 2015 Forms 1094-B, 1095-B, 1094-C and 1095-C with the IRS, from Feb. 29, 2016, to May 31, 2016, if not filing electronically, and from March 31, 2016, to June 30, 2016, if filing electronically. 

Despite the delay, employers and other coverage providers are encouraged to furnish statements and file information returns as soon as they are ready.

 

Filers are not required to submit any request or other documentation to the IRS to take advantage of the extended due dates provided by Notice 2016-4.

Extended Due Dates are Automatic

 Filers are not required to submit any request or other documentation to the IRS to take advantage of the extended due dates provided by Notice 2016-4.

 Because these extensions apply automatically to all filers and are more generous than extensions for 2015 returns and statements that have already been requested by some filers, those requests will not be formally granted. 

The previous provisions regarding extensions of time for filing information returns and furnishing statements will not apply to the extended due dates.

These extensions for the Sections 6055 and 6056 information reporting provisions for calendar year 2015 have no effect on the information reporting provisions for other years or on the effective date or application of other ACA provisions.