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A Better Partnership


Dec 2018
December 04, 2018

Affordable Care Act Reporting Relief: IRS Extends 1095-B/1095-C Distribution Deadline

Employers and insurers subject to ACA reporting requirements received an early holiday gift. The IRS has decided to give employers and insurers an additional month to furnish ACA information forms to individuals. The relief, however, does not extend to the forms that must be filed with the IRS.

Under IRS Notice 2018-94, the deadline to furnish the following forms to individuals has been extended from January 31, 2019, to March 4, 2019:
  • 2018 Form 1095-B, Health Coverage; and
  • 2018 Form 1095‑C, Employer-Provided Health Insurance Offer and Coverage

The IRS will not allow any other deadline extensions for these forms. If you can’t meet the extended deadline, you should furnish the forms as soon as possible, as the IRS may abate penalties if you can demonstrate reasonable cause for not meeting the deadlines.

The deadline for filing the following forms with the IRS remains February 28, 2019 (if not filing electronically), and April 1, 2019 (if filing electronically):
  • 2018 Form 1094-B, Transmittal of Health Coverage Information Returns with individual 2018 Forms 1095-B; and
  • 2018 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns with individual 2018 Forms 1095-C.

Automatic extensions of 30 days are available for these forms by filing Form 8809, and additional extensions of fewer than 30 days are also possible (but not automatic).

IRS Notice 2018-94 also provides relief from penalties for incorrect or incomplete information on the ACA reporting forms when a reporting entity can show it made a good faith effort to comply with the information reporting requirements. As in past years, this relief only applies if the reporting entity filed its forms on a timely basis.

If you have questions about ACA reporting requirements please contact Norbert Kugele, Stephanie Grant or any other member of Warner’s Employee Benefits Practice Group.

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