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Filing Delay for Forms 1094 and 1095

Employers are struggling to collect, analyze, and report the extensive amount of information for minimum essential coverage (MEC) and employer mandates. The “Extension of the Due Dates for 2015 Information Reporting Under I.R.C. Sections 6055 and 6056,” commonly known as Forms 1094 and 1095 filings, was released by the Internal Revenue Service (IRS) December 28, 2015. Notice 2016-4 affords employers an automatic extension of time to send individual forms to their employees and submit forms to the IRS.

This filing delay applies to insurers, self-insuring employers, and certain other providers of MEC, plus reporting requirements for applicable large employers (ALEs). The IRS is prepared to accept filings starting January 2016, but understands that filers may need additional time. No letter or extension request needs to be sent to the IRS by employers utilizing this transition relief.

Recap of ACA Filing Requirements

For an outline of filing requirements, please see our Compliance Alert "Update to the Affordable Care Act Reporting Requirements" and "Affordable Care Act Reporting Requirements."

Extended due dates for employers who do not file electronically*:
  Original Due Date   Extended Due Date
2015 Form 1095-B (MEC Health Coverage) to individuals

2/1/2016 3/31/2016
2015 Form 1094-B (MEC) transmittal to IRS

2/29/2016 5/31/2016
2015 Form 1095-C (Enrollment) to individuals

2/1/2016 3/31/2016
2015 Form 1094-C (Offer and Coverage) transmittal to IRS

2/29/2016 5/31/2016

Extended due dates for employers who file electronically
2015 Form 1094-B (MEC) transmittal to IRS

3/31/2016 6/30/2016
2015 Form 1094-C (Offer and Coverage) transmittal to IRS

3/31/2016 6/30/2016

*Non-electronic filing is only available to employers who file fewer than 250 Forms to individuals

Individuals Filing 2015 Tax Return Prior to Receipt of Form 1095-B or Form 1095-C

Most individuals will not be affected by these extensions. Employees are not eligible for premium tax credits for any month if the employee is eligible for coverage that provides minimum value (MV) and is affordable. Employees enrolled in an eligible employer-sponsored plan are also not eligible for premium tax credits. This data is generally collected at the Marketplace prior to the purchase of insurance coverage. However, some employees who enrolled in coverage through the Marketplace may not receive the needed information concerning MEC prior to filing their tax returns. These individuals need not file an amended return or send this information to the IRS. They just need to keep it with their 2015 tax records.

Filing extensions are only for the 2015 Forms and do not apply to any other calendar year filings in the future. Employers not meeting the extended due dates will be subject to penalties outlined in IRS Code Sections 6722 and 6721. However, latitude can be given to abate penalties for reasonable cause.

Click here for a downloadable copy of this report.