By Cynthia Moore

The Affordable Care Act (ACA) established new reporting requirements that apply to applicable large employers (with 50 or more full-time employees) and health coverage providers. Reporting begins in calendar year 2015. The new reporting rules are intended to assist the IRS in enforcing the ACA’s employer mandate to offer affordable, minimum value coverage to full-time employees and the individual mandate to maintain health coverage or pay a penalty.

In Notice 2016-4, issued on December 28, 2015, the IRS extended the deadlines for furnishing the 2015 Form 1095-C to employees and for filing the 2015 Forms 1094-C/1095-C with the IRS. The extended deadlines are:

Original Deadline
New Deadline
Date for furnishing copies of Form 1095-C to employees
February 1, 2016
March 31, 2016
Date for filing Forms 1094-C/1095-C with the IRS (if filing via hard copy)
February 29, 2016
May 31, 2016
Date for filing Forms 1094-C/1095-C with the IRS (if filing electronically)
March 31, 2016
June 30, 2016

The extension also applies to the furnishing and filing of 2015 Forms 1094-B/1095-B (primarily by insurers).

The IRS issued this extension because it received input that employers and insurers need additional time to implement systems and procedures to gather, analyze and report the information required by the Forms.

If you have any questions, please feel free to call Cyndi Moore in our Troy, Mich. office at 248-433-7295 or any member of the Employee Benefits team.