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Nov 2016
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November 21, 2016

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


Employers and insurers subject to ACA reporting requirements might want to give thanks this week for a deadline extension. 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 2016-70, the deadline to furnish the following forms to individuals has been extended from January 31, 2017, to March 2, 2017:
  • Health Coverage 2016 Form 1095-B; and
  • Employer-Provided Health Insurance Offer and Coverage 2016 Form 1095‑C.
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, 2017 (if not filing electronically) and March 31, 2017 (if filing electronically):
  • Transmittal of Health Coverage Information Returns 2016 Form 1094-B with individual Health Coverage 2016 Forms 1095-B; and
  • Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns 2016 Form 1094-C with individual Employer-Provided Health Insurance Offer and Coverage 2016 Form 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).

If you have questions about ACA reporting requirements, please contact Norbert Kugele at nkugele@wnj.com or 616.752.2186 or Kent Sparks at ksparks@wnj.com or 616.752.2295.

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