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ACA Proposed Reporting Deadline Extension

Employee Benefits

On November 22, 2021, the Department of Treasury along with the Internal Revenue Service (IRS) released proposed regulations that would permanently extend the deadline for Applicable Large Employers (ALEs) under the ACA to provide IRS Form 1095Cs to full-time employees. In addition, the proposed regulations would allow entities providing 1095Bs and self-funded ALEs providing 1095Cs to part-time or retired/terminated employees to post contact information on their website for individuals to request the forms rather than providing them directly. Self-funded ALEs would still need to provide the full 1095C form to all full-time employees.

Although these are proposed regulations, the applicability provision allows ALEs to rely on the proposed changes for the 2021 reporting period. As a result, the deadline for providing 1095Cs to full-time employees is extended from January 31, 2022 to March 2, 2022.

Please note that the deadlines for providing the 1095C forms to the IRS have not changed. The following deadlines for 2022 are still in place:

  • File by Mail: February 28, 2022
  • File Electronically: March 31, 2022

If approved, the deadline to provide 1095Cs to full-time employees would be permanently extended to 30 days after January 31 of each year without requiring ALEs to request such extension. 

Key Takeaway

If this rule is officially implemented, Applicable Large Employers (ALEs) would still have reporting responsibilities under the ACA, however this would permanently provide a longer amount of time for ALEs to provide 1095C forms to full-time employees. Employers who qualify as ALEs would be well-served to prepare for their annual reporting under current ACA rules with this extension in mind.

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