HORAN Health Benefits Compliance Blog

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IRS 6055 and 6056 Reporting Delay: Forms 1095-C Filing Extension

 November 21 2016     Shelly Hodges-Konys
The IRS issued a Notice announcing an extension to the deadline for distribution of Forms 1095-C to individuals. After extensive pressure from the industry, the IRS has agreed to give employers a 30-day extension to this deadline for the 2016 calendar year filings only. This means that Forms 1095-C must be distributed to individuals no later than March 2, 2017.

Under the Affordable Care Act, individuals are required to have health insurance, while applicable large employers are required to offer health benefits to their full-time employees. In order for the IRS to verify these ACA requirements, all large employers must complete and distribute a Form 1095-C to any employee who was considered a full-time employee for one or more months of the calendar year. The normal deadline for distributing Forms is January 31st of the following year. This 30-day extension will be welcome news to large employers and their vendors who are trying to gather information and prepare their Forms. However, due to this automatic extension, the IRS will not be granting additional 30-day extensions upon request for Forms 1095-C distribution to individuals. Therefore, employers must ensure that they distribute their Forms 1095-C to all full-time employees no later than March 2nd.

Unlike last year, the IRS is NOT extending the due date for filing Forms 1094-B and 1094-C and copies of Forms 1095-B and 1095-C with the IRS. For employers that are filing electronically, this deadline remains March 31, 2017. For employers who are filing paper forms (permissible only if you are filing 250 or fewer Forms 1095-C), the deadline remains February 28, 2017. Employers may still apply for extensions of time for filing Forms 1094-C and 1095-C to the IRS. To do so, Form 8809 must be filed by the due date of the applicable return in order to be granted the 30-day extension.

The IRS reiterated that the notice also extends the good faith transition relief for another year, which is also good news for employers and vendors alike as they continue to digest these complicated reporting requirements. This good faith transition rule provides relief for the reporting penalties to employers that can demonstrate they made a good-faith effort to comply with the requirements. It is important to note that, like last year, this good faith relief is only available to those employers who timely submitted Forms 1094-C and 1095-C. It is not available for failure to timely furnish or file a Form. Therefore, employers who are still struggling to gather correct information by the deadline should timely file their Forms with the incomplete or incorrect information and correct it later rather than filing correct forms late.

Please contact your HORAN representative with any questions.