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Filing Delay for Forms 1095-B and 1095-C

Notice 2016-70, released November 18, 2016, extends the due dates for 2016 individual reporting requirements. Under section 6055 and 6056 of the Affordable Care Act (ACA), commonly known as Forms 1094 and 1095 filings, this notice affords employers an automatic extension of time to send individual forms to their employees. This notice also provides for transitional good-faith relief from the penalties imposed by the Internal Revenue Code relating to the 2016 information reporting requirements. No request or form needs to be sent to the IRS by employers utilizing this extension or 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 Electronic Filings Original Due Date Extended Date
2016 Form 1095-B, Health Coverage; to individuals January 31, 2017 March 2, 2017
2016 Form 1094-B, Transmittal of Health Coverage Information Returns; to IRS March 31, 2017 N/A
2016 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage; to individuals January 31, 2017 March 2, 2017
2016 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns; to IRS March 31, 2017 N/A

 

In view of this automatic extension for furnishing information to individuals, the provisions for extensions requested by employers and granted by the Internal Revenue Service (IRS) will not apply to the extended due dates. However, extensions for filings with the IRS can be extended by filling out and submitting Form 8809.

Extensions are only for the 2016 forms, filed in 2017, and do not apply to any other calendar year filings in the future. Employers not meeting the original or extended due dates, as applicable, will be subject to penalties outlined in IRS Code Sections 6722 and 6721. However, latitude can be given to abate penalties for reasonable cause.

The IRS is prepared to accept filings starting January 2017, but understand that filers may be additional time.

Download a copy of this Alert.