IRS Issues 2016 ACA Reporting Deadline Extension

Last January we told you about some deadline extensions for ACA reporting forms 1094 and 1095. Here we are, 11 months later, to tell you that new deadline extensions have been announced by the Internal Revenue Service (IRS). This time there will be a delay in the date that forms are due to individuals.

Extension of Reporting Requirements

Under Internal Revenue Code (IRC) Section 6055, health coverage providers are required to file with the IRS, and distribute to covered individuals, forms showing the months in which the individuals were covered by “minimum essential coverage.” Under IRC Section 6056, applicable large employers (generally those with 50 or more full-time employees and equivalents) are required to file with the IRS, and distribute to employees, forms containing detailed information regarding offers of, and enrollment in, health coverage.

On November 18, 2016, the IRS issued Notice 2016-70, which extends the due date for the 2016 requirement to furnish ACA-related statements to individuals for insurers, self-insuring employers, and applicable large employers. Specifically, the IRS has extended the due date for furnishing the 2016 Form 1095-B, Health Coverage, and the 2016 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage as follows:

• OLD: January 31, 2017
• NEW: March 2, 2017

The due dates for providing 2016 Forms 1095 to the IRS remain the same:

• February 28, 2017 (paper); March 31, 2017 (electronic)

Guidance to Individuals

Similar to last year, Notice 2016-70 also provides guidance to individuals who might not receive a Form 1095-B or Form 1095-C by the time they file their 2016 tax returns.

For 2016 only, individuals who rely upon other information received from employers about their offers of coverage for purposes of determining eligibility for the premium tax credit when filing their income tax returns need not amend their returns once they receive their Forms 1095-C or any corrected Forms 1095-C. Individuals need not send this information to IRS when filing their returns but should keep it with their tax records in case of an audit.

Similarly, some individual taxpayers may be affected by the extension of the due date for providers of minimum essential coverage to furnish information under IRC Section 6055 on either Form 1095-B or Form 1095-C. Because of the extension, individuals may not have received this information before they file their income tax returns. For 2016 only, individuals who rely upon other information received from their coverage providers about their coverage for purposes of filing their returns need not amend their returns once they receive the Form 1095-B or Form 1095-C or any corrections. Individuals need not send this information to the Service when filing their returns but should keep it with their tax records.