INSIGHTS ABOUT HEALTH CARE REFORM

DECEMBER 30, 2015  

IRS Extends ACA Information Reporting Deadlines
 
The IRS issued guidance on December 28 that extended the due dates for the 2015 information reporting requirements for applicable large employers under IRS code section 6056 and for insurers, self-insuring small employers, and some other providers of minimum essential coverage under code section 6055. These reporting forms, Form 1095-C and Form 1095-B respectively, were originally to be postmarked to employees and participants by January 31, 2016. The original due date to send the forms to the IRS along with the 1094 transmittal form was February 29, 2016, if paper filed and March 31, 2016, if e-filed.
 
New Deadlines
With the issuance of IRS Notice 2016-4, employers now have until March 31, 2016, to provide employees Form 1095-B or 1095-C, whichever is applicable for reporting offers of health coverage and/or coverage provided. The deadlines to send these forms to the IRS is now extended by three months to May 31, 2016, for paper filers and June 30, 2016, for electronic filers. 
 
Although this is good news for employers who are still gathering information for the reporting forms, the IRS is encouraging employers and/or coverage providers to file the forms as soon as possible. Employers and coverage providers that have already submitted a request for an extension on these forms will not receive a formal extension from the IRS, as the extension provided in Notice 2016-4 is more generous.
 
What Doesn't Change
This extension will not affect most taxpayers, so they should proceed with filing their individual tax returns. Employees who enrolled in Marketplace coverage and did not receive a determination from the Marketplace that their employer coverage was unaffordable should rely on other information received from their employers to determine whether or not they qualify for a premium tax credit. Similarly, taxpayers may rely on other information provided by their coverage provider to determine whether or not they had minimal essential coverage for 2015. Taxpayers relying on the information provided by their employer as to the offer of coverage and from their provider as to what months coverage was offered will not need to amend their returns once they receive Form 1095-C and/or 1095-B. However, they should keep these forms in their tax records.
 
For additional information, contact your Eide Bailly service provider, one of our health care reform specialists at healthcarereform@eidebailly.com or 855.220.8634, or review our updated article.  
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