IRS Delivers Belated Christmas Gift – Extends ACA Reporting Deadlines

The IRS delivered a late Christmas gift December 28, 2015 when, in Notice 2016-4, it extended the Affordable Care Act (“ACA”) reporting deadlines.  The new deadlines affect distribution and filing of Forms 1094 and 1095 for calendar year 2015 and are provided below.

Section 6055 Health Coverage Reporting
	Old Filing Deadline	New Filing Deadline
Form 1095-B (to employees)	February 1, 2016*	March 31, 2016
Form 1094-B (to IRS)	February 29, 2016 (paper filing) March 31, 2016 (electronic filing)	May 31, 2016 (paper filing) June 30, 2016 (electronic filing)

Section 6056 Employer-Provided Health Insurance Offer and Coverage Reporting
	Old Filing Deadline	New Filing Deadline
Form 1095-C (to employees)	February 1, 2016*	March 31, 2016
Form 1094-C (to IRS)	February 29, 2016 (paper filing) March 31, 2016 (electronic filing)	May 31, 2016 (paper filing) June 30, 2016 (electronic filing)

In light of this transitional relief, the IRS will not accept automatic or permissive extensions for filing Forms 1094 and 1095. Employers may wish to continue to gather the information required to complete their returns and file as soon as they are ready.

For more information about Forms 1094 and 1095, see our October 6, 2015 SW Benefits Blog post “Final Forms and Instructions for ACA Information Reporting Released.”