Shortly before the Thanksgiving holiday, the IRS issued a Notice extending one of the due dates for 2016 information reporting under the Affordable Care Act. Insurers, self-insuring employers, certain providers of minimum essential coverage and applicable large employers now have until March 2, 2017, to provide Forms 1095-B (Health Coverage) and 1095-C (Employer-Provided Health Insurance Offer and Coverage) to individuals. Good-faith transition relief from certain penalties has also been extended. Employers now have an additional 30 days to issue these forms to their employees with no extension request required to be sent to the IRS.
There is no additional extension to send in these forms (also including Forms 1094-B, Transmittal of Health Coverage Information Returns, and 1094-C, Transmittal of Employer Health Insurance Offer) to the IRS. These are still due (along with respective copies of Forms 1095-B and 1095-C) either Feb. 28, 2017, if filing by mail or March 31, 2017, if filing electronically. Form 8809, Application for Extension of Time to File Information returns, is available if an extension is needed to compile information necessary to accurately complete these forms.
Employers that do not comply with the extended due date under this Notice (or a formal extension using Form 8809) will be subject to failure to timely furnish and file information reports. Employers that rely on a third-party service provider to complete 2016 ACA reporting obligations, confirm with that service provider what impact, if any, this delay will have on reporting deliverables and related deadlines.
Individual taxpayers who do not receive their 1095-B or 1095-C forms prior to filing their 2016 personal income tax returns may rely on other information provided by their employers to confirm they carried or were offered minimum essential coverage. Other information may include Form W-2 (Wage and Tax Statement), Summaries of Benefits and Coverage, benefits enrollment materials as well as enrollment websites.