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IRS Extends ACA Form Deadline

 Employers now have until March 2, 2017 to issue 1095-B/C forms to employees

 J. Edward McClements, Jr. - Sr. Vice President - Benefits

 Barkley Insurance & Risk Management

November 25, 2016

 On November 18 the IRS issued Notice 2016-70.  This notice gives large employers additional leeway to complete their 1094/1095 filing obligations for the 2016 year in two important ways:

  •  The IRS extended the deadline to deliver ACA reporting forms to employees from Jan. 31st  to Mar. 2nd, 2017.
  • It also extends the “good faith transition relief” for another year (whereby the IRS promises it will not penalize employers for incorrect or incomplete forms if they can show they made good-faith efforts to comply with the reporting requirements).

The IRS also noted that the relief applies to “missing and inaccurate taxpayer identification numbers and dates of birth.”

 The extended deadline applies to furnishing to individuals the 2016 Form 1095-C (Employer-Provided Health Insurance Offer and Coverage) and Form 1095-B (Health Coverage).

 This extension applies for tax year 2016 only, and does not require the submission of any formal request or other documentation to the IRS.  No relief is available to employers who did not timely file the forms.

 Like last year, the guidance provides that taxpayers can file their personal income tax return without having to attach the relevant Form 1095 to their tax returns.  Taxpayers should keep these forms in their personal records.

 It is critical to note that the IRS did not change the deadline for filing Forms 1094 and 1095 with the IRS itself. This means there will be no extension to file the 2016 Form 1094-B (with 1095-B copies) and Form 1094-C (with copies of Form 1095-C). 

Employers filing these forms by mail will still need to do so by Feb. 28, 2017.  Employers filing electronically (remember - ALEs submitting 250 or more forms are required to do so) must file by March 31.