IRS Extends Due Dates For 2015 ACA Reporting Requirements

On December 28, 2015, the IRS extended the due dates for new health care information reporting forms in 2016. Insurers, self-insuring employers, other coverage providers, and applicable large employers now have additional time to provide health coverage information for 2015 to individual taxpayers and the IRS. 

Specifically, in Notice 2016-4, the regulators extended the deadlines:MXLLS

• The due date for furnishing these forms is extended.

  • The due date for furnishing the 2015 Form 1095-B and the 2015 Form 1095-C to the insured and employees is extended from January 31, 2016, to March 31, 2016.

  • The due date for health coverage providers and employers furnishing the 2015 Form 1094-B and the 2015 Form 1094-C to the IRS is extended from February 28, 2016, to May 31, 2016 if not filing electronically.

  • The due date for health coverage providers and employers electronically filing the 2015 Form 1094-B and the 2015 Form 1094-C with the IRS is extended from March 31, 2016, to June 30, 2016.

• While the IRS is prepared to accept information reporting returns beginning in January 2016 and employers and other coverage providers are encouraged to furnish statements and file the information returns as soon as they are ready.

• An ALE is required to file Form 1094-C with the IRS; however, an ALE is not required to furnish a copy of Form 1094-C to its full-time employees. 

• Generally, an ALE must file Form 1095-C or a substitute form for each employee who was a full-time employee for any month of the calendar year.

• In addition, an ALE that sponsors a self-insured plan must file Form 1095-C for each employee who enrolls in the self-insured health coverage or enrolls a family member in the coverage, regardless of whether the employee is a full-time employee for any month of the calendar year.

• Form 1095-C is not required for the following employees, unless the employee or the employee's family member was enrolled in a self-insured plan sponsored by an ALE member:

  • An employee who was not a full-time employee in any month of the year.

  • An employee who was in a limited non-assessment period for all 12 months of the year.

• If an ALE member sponsors a health plan that includes self-insured options and insured options, the ALE member should complete Part III of Form 1095-C only for employees and family members who enroll a self-insured option. 

• An ALE member that offers coverage through an employer-sponsored insured health plan and does not sponsor a self-insured health plan should NOT complete Part III.

• An ALE may provide a substitute Form 1095-C; however, the substitute form must include the information on Form 1095-C and must comply with generally applicable requirements for substitute forms.

For more information, on forms 1094-C and 1095-C, click on the links listed below. 

• Click this secure link for 1094-C instructions.

• Click this secure link for 1095-C instructions.

Key Information To Note:

The IRS has not extended the due dates for Health Insurance Marketplaces to issue Form 1095-A. Individuals who enrolled for coverage through the Marketplace should receive Form 1095-A by February 1, 2016 and should wait to file their returns until the receive their Form 1095-A.

Questions And Answers For New Information Reporting Forms.

The IRS has posted a set of FAQs for Forms 1095-B and 1095-C. The questions and answers explain who should expect to receive the forms, how they can be used, and how to file with or without the forms. To learn more about these FAQs, click this secure link.