December 29, 2015 
IRS Notice 2016-4 extends the due dates for the 2015 ACA information reporting requirements applicable to self-insuring employers, large employers and other providers of minimum essential coverage. 
 
2015 Deadline Extension
Specifically, the notice extends the due date:
  • For furnishing 2015 Forms 1095-B and 1095-C to individuals
    •  from February 1, 2016, to March 31, 2016
       
  • For filing 2015 Forms 1094-B, 1095-B, 1094-C and 1095-C with the IRS
    • from February 29, 2016, to May 31, 2016 (if not filing electronically) 
    • from March 31, 2016, to June 30, 2016 (if filing electronically)
As a reminder, Forms 1094-B and 1095-B will be used by self-insuring employers that are not considered applicable large employers, and other parties that provide minimum essential health coverage, to report information to the IRS and to covered individuals. Applicable large employers- those with 50 or more full-time employees or equivalents - will use Forms 1094-C and 1095-C to report information to the IRS and to their employees about the health care coverage they've offered.

Note: Employers subject to both reporting provisions (self-insured employers with 50 or more full-time employees, including FTEs) will satisfy their reporting obligations using Forms 1094-C and 1095-C. Form 1095-C includes separate sections for reporting under each provision.
 
Extension Applies for 2015 Calendar Year Only
The extensions for the ACA information reporting requirements apply for calendar year 2015 only and have no effect on the requirements for other years or on the effective dates or application of the ACA "pay or play" provisions. In view of these extensions, the IRS rules regarding automatic and permissive extensions of time for filing information returns and permissive extensions of time for furnishing statements will not apply to the extended due dates. Employers or other coverage providers that do not comply with these extended due dates will be subject to penalties.

Read the full IRS Notice HERE.  
This Employment Law Alert provided by:
United Employers Association
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