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ACA UPDATE: IRS Delays 2016 Reporting Deadlines

Employee Benefits

Delay in place for applicable large employers

On November 18, 2016, the Internal Revenue Service (IRS) issued IRS Notice 2016-70.  This notice announces that the IRS has delayed some Affordable Care Act (ACA) reporting due dates and also has extended good faith transitional relief for 2016.  This guidance applies to all applicable large employers (ALEs) with 50+ employees.

According to the IRS notice, the following filing deadlines were DELAYED:

  • Individual/Employee Forms: The deadline for sending Forms 1095-B and 1095-C to individuals (employees) has been delayed from January 31 to March 2, 2017.
  • Good Faith Transition Relief: Reporting entities (including employers) that can show they made a good-faith effort to comply with the 2016 information reporting requirements will not be subject to penalties otherwise applicable to filing incorrect or incomplete information on a return or statement.   No relief is provided where an employer fails to file an information return or fails to furnish a statement within the due dates.
  • Extensions: In light of this relief, the IRS has stated that no further extensions of due dates associated with sending Forms 1095-B and 1095-C to individuals will be granted.

The following filing deadlines REMAIN UNCHANGED:

  • Forms to IRS (Paper): The deadline for filing Forms 1094-B, 1095-B, 1094-C, and 1095-C to the IRS via first-class mail is February 28, 2017.
  • Forms to the IRS (Electronic): The deadline for filing forms 1094-B, 1095-B, 1094-C, and 1095-C to the IRS electronically is March 31, 2017.
  • Automatic Extensions (Paper Filings): Employers can obtain an automatic 30-day extension by submitting
    Form 8809 to the IRS on or before the due date.
  • Hardship Waiver (Electronic Filing): An employer may request a hardship waiver from the electronic filing requirements by submitting Form 8508 at least 45 days before the due date of the returns.  The principal factor in evaluating “hardship” is considering the cost of filing electronically.

Key Takeaway

For the 2015 filing requirements, the IRS automatically extended due dates for providing individuals with a Form 1095-B or 1095-C and delayed the deadline to file these forms with the IRS.  The extension for 2016 only delays compliance with providing individuals with their information returns.

M3 has a number of resources available to you on the topic of IRS Reporting for Section 6055 and 6056.  The M3 Health Care Reform Tracker has reference materials designed to help you remain compliant with ACA regulations.  If you have further questions or concerns, please contact your M3 Account Team.

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