Deadline for ACA Reporting Extended

Quantifying the Population Health Management Investment

The Internal Revenue Service (IRS) has extended the deadline for applicable employers and other health coverage providers to furnish 1094 and 1095-B and C series forms required by the Affordable Care Act (ACA). The deadline for furnishing individuals with 2015 Form 1095-B and 2015 Form 1095-C has been extended from February 1, 2016, to March 31, 2016. The IRS’s recent notice also extends the due date for employers and other health coverage providers to file with the IRS 2015 Form 1094-B and 2015 Form 1094-C from February 29, 2016, to May 31, 2016, if not filing electronically, and from March 31, 2016, to June 30, 2016, if filing electronically. Any employer filing 250 or more forms is still required to file electronically.

The extension provides employers with more time to gather the necessary data to generate and submit the required forms. Some of the ACA’s reporting requirements apply only to large employers (those with 50 or more full-time employees or full-time equivalents) and are meant to demonstrate compliance with the employer shared-responsibility mandate (“Pay or Play”) and eligibility for premium tax credits. Other reporting requirements apply to all employers, insurers, or other coverage providers that provide employees with minimum essential coverage to enable the IRS to enforce the individual mandate.

The extension provides a small measure of relief to many employers or their vendors, if applicable, who were in need of additional time to aggregate and calculate the data necessary for reporting purposes. The IRS forms require employers and other coverage providers to gather detailed information such as an employer’s monthly offer of health coverage to full-time employees, the employee’s share of premium, monthly enrollment information for covered individuals, their spouses and dependents, and identifying information such as tax identification numbers, and addresses, for example.  As this is the first year employers were required to document such data, many are still formulating processes to accumulate the information needed.

The IRS will still accept filings of the information returns on Forms 1094-B, 1095-B, 1094-C, and 1095-C beginning in January 2016 from any entity prepared to submit in January. The IRS intends to take a good-faith enforcement approach to this first year of reporting, however it is important to note that employers that do not meet the extended deadlines will still be subject to ACA penalties for failure to timely furnish and file the required forms. Employers utilizing software or payroll vendors to assist with their IRS filings should confirm with their vendors any applicable deadlines for data submission.