On December 28, 2015, the IRS released Notice 2016-4, which extends the due dates for the 2015 Affordable Care Act information reporting requirements for self-insuring employers and applicable large employers under sections 6055 and 6056 of the Internal Revenue Code.
The Notice extends three critical reporting deadlines for the 2015 reporting year only:
- The due date for furnishing Forms 1095-B and 1095-C to individuals is extended from February 1, 2016 to March 31, 2016;
- The due date for filing Forms 1094-B and 1095-B, or Forms 1094-C and 1095-C, to the Internal Revenue Service is extended from February 29, 2016 to May 31, 2016 if not filing electronically; and
- The due date for filing Forms 1094-B and 1095-B, or Forms 1094-C and 1095-C, to the Internal Revenue Service is extended from March 31, 2016 to June 30, 2016, if filing electronically.
While the extended deadlines bring welcome relief to many, employers should not get too comfortable. The IRS states that in light of the extended deadlines, no requests will be granted for further extensions of time to file or furnish statements. In other words, these extended deadlines are fixed for every employer. Employers should continue their good faith efforts to meet the filing requirements, as failure to comply with these extended due dates will result in the imposition of penalties.
Individuals who rely on information received from employers or coverage providers about their offers of coverage to determine their eligibility for the premium tax credit will not be required to amend their 2015 income tax returns in the event that they receive Form 1095-B or 1095-C after filing their return.