It doesn’t happen often, but the IRS has listened to concerns and is giving companies a break this year. The reporting deadline for the new ACA Forms 1094-C and 1095-C has been extended, giving companies a bit of breathing room with these new forms.
The IRS issued Notice 2016-4 on Dec 28, 2015. This notice extends the reporting deadline for Form 1095-C from February 1 to March 31, 2016 and the deadline for Form 1094-C from Feb 29 to May 31, 2016 (and if you file electronically, it’s extended to June 30, 2016).
While the IRS is prepared to accept returns starting in January, the extension will allow companies more time to acclimate to the new reporting requirements. For companies using a product like Payce’s ACA Dashboard, reporting won’t be an issue, but for those manually gathering information this is very welcome news.
As a reminder, all employers with 50 or more full-time equivalent employees will be required to report health coverage on Form 1095-C. This is the form that will also be distributed to employees. Form 1094-C functions as the transmittal document (think “cover sheet”) for sending all of the 1095-C’s to the IRS.
The Notice also provides guidance for individuals who may not receive their Form 1095-B or Form 1095-C before they file their returns. The Notice clarifies that individuals do NOT need to include Form 1095-C with their personal tax returns, but may instead use “other information received from their coverage providers” to confirm they either have coverage or are eligible for a premium tax credit. Employers who have not automated ACA reporting and are struggling with the requirements may want to issue a “statement of coverage” that employees can use in preparing their 2015 taxes.
The ACA reporting requirements are complex, and penalties can be assessed for companies that fail to meet them. Remember, if you have questions or need assistance, Payce is here to help.