IRS Extends Some Affordable Care Act (ACA) Deadlines to Help Companies Meet Requirements [Blog Post]

The following “Expertise Beyond the Numbers” blog post from SC&H Group discusses the extension of some of the ACA reporting requirements for employers by the IRS.

The Internal Revenue Service (IRS) has extended the due dates for the health insurance informational returns required to be furnished to individuals and to the IRS under the Patient Protection and Affordable Care Act.

The due date for information returns required to be sent to individuals listing their health insurance coverage, Form 1095-B Health Coverage, and Form 1095-C Employer-Provided Health Insurance Offer and Compromise has been extended from January 31, 2016 to March 31, 2016.

In addition, the due date for filing the Forms 1094-B, 1095-B, 1094-C and 1095-C with the IRS has been extended to May 31, 2016 from February 29, 2016, if not filing electronically, and to June 30, 2016 from March 31, 2016, if filing electronically.

The Internal Revenue Service continues to provide fact sheets to aid employers in complying with the Affordable Care Act. In addition to the extensions listed above, “Tax Tip 2015-85” lists seven basic facts for large employers:

  1. An applicable large employee (“ALE”) is required to file Form 1094-C with the IRS; however, an ALE is not required to furnish a copy of Form 1094-C to its full-time employees.
  1. Generally, an ALE must file Form 1095-C or a substitute form for each employee who was a full-time employee for any month of the calendar year.
  1. An ALE that sponsors a self-insured plan must file Form 1095-C for each employee who enrolls in the self-insured health coverage or enrolls a family member in the coverage, regardless of whether the employee is a full-time employee for any month of the calendar year.
  1. Form 1095-C is not required for the following employees, unless the employee or the employee’s family member was enrolled in a self-insured plan sponsored by an ALE member:
  • An employee who was not a full-time employee in any month of the year.
  • An employee who was in a limited non-assessment period for all 12 months of the year.
  1. If an ALE member sponsors a health plan that includes self-insured options and insured options, the ALE member should complete Part III of Form 1095-C only for employees and family members who enroll a self-insured option.
  1. An ALE member that offers coverage through an employer-sponsored insured health plan and does not sponsor a self-insured health plan should NOT complete Part III.
  1. An ALE may provide a substitute Form 1095-C; however, the substitute form must include the information on Form 1095-C and must comply with generally applicable requirements for substitute forms.

Are you prepared for the impact of this new reporting? If you are an Applicable Large Employer, and would like to discuss the extension of the ACA reporting requirements, please contact SC&H Group here.