2015 ACA Reporting Extension Offers Employers IRS Relief

With the New Year underway, employers have an extra reason to celebrate: Just before the end of the year, the Internal Revenue Service released Notice 2016-4, which extends due dates for the 2015 information reporting required by the Affordable Care Act. As we reported in our ThinkHR newsletter, this gives employers an additional two months to supply employees with the appropriate forms and an extra three months to submit the completed forms to the IRS. “As we implement this law, we have and will continue to make changes as needed,” said Valerie Jarrett, a senior Obama adviser when the law was originally being implemented in 2013. “In our ongoing discussions with businesses we have heard that you need the time to get this right.” This is yet another extension granted to employers by the federal government to ease the transition to the ACA, going all the way back to 2014. In particular, medium-sized businesses have been allowed some timing accommodations. A mandate issued in February 2014 allowed businesses over the 50-employee threshold but under 99 employees to have an extra year to file information about their health care coverage. “The administration has finally recognized the obvious — employers need more time and clarification of the rules of the road before implementing the employer mandate,” Randy Johnson, a senior vice president at the U.S. Chamber of Commerce, said at the time of the original mandate. These applicable large employers are required to provided Form 1095-C to the employee or former employee and file copies, along with transmittal Form 1094-C, with the IRS. Employers sponsoring an employee self-funded and insured health plan providing the minimum required coverage are required to provide coverage information about enrollees, regardless of the size of the business. Due dates for employers following the issuing of Notice 2016-4 are broken down as follows:

• 2015 forms Form 1095-C, or Form 1095-B, if applicable, must be issued to employees and individuals by March 31, 2016 (extended from February 1, 2016)
• When filing the 2015 Forms 1095-C along with transmittal Form 1094-C, or Forms 1095-B with transmittal Form 1094-B, if applicable, the deadline is:
  • By paper, May 31, 2016 (extended from February 29, 2016).
  • Electronically, June 30, 2016 (extended from March 31, 2016).

These deadlines have gone into effect automatically without needing a formal request to be approved. Notice 2016-4 also instructs taxpayers who do not receive a Form 1095-B or 1095-C by the time they file their 2015 individual tax return how to remedy the filing. Finally, as part of the release, the IRS encourages all employers, insurers, and other reporting entities to make the forms available to employees in a timely, expedient fashion.