The IRS is extending one of the deadlines for providing 2016 Affordable Care Act (ACA) information statements to recipients. The deadline for providing individuals with 2016 Form 1095B Health Coverage and the 2016 Form 1095C is now March 2nd 2017, instead of January 31st.

FAQs about the Extension

1. Why is it being extended? The IRS consulted with employers, insurers and other providers of minimum essential coverage and came to the conclusion that many needed additional time.
2. Is the extension automatic? Yes.
3. Is the deadline for filing the forms with the IRS extended under this ruling? No, the filing deadline with the IRS remains February 28th, 2017 (March 31st for e-filing) for employers, insurers, and other providers of minimum essential coverage to file 2016 Forms 1094B, 1095B, 1094C and 1095C.
4. Who must furnish these statements? The following must file annual returns:

• Health insurance issuers

• Sponsors of self-insured health plans

• Government agencies that administer government-sponsored health insurance programs

• Other providers of minimum essential coverage - the ACA requires applicable large employers (typically those with at least 50 full-time employees - which includes full-time equivalent workers from the previous year) to provide employees with Form 1095C

5. Why are these statements provided to employees? The IRS wants to verify that the taxpayers were covered by minimum essential coverage, and they'd like to know employees' months of ACA enrollment during a calendar year.
6. Does documentation need to be submitted to receive the extension from the IRS? No, the extension is automatic.

What about penalty relief?

The same penalty relief allowed on 2015 returns is being extended to 2016 returns. IRS Notice 2016-70 extends the “good faith penalty relief” from penalties for failure to timely furnish and file the information returns from the previous year to 2016.

What exactly falls under “good faith”? The IRS will consider whether an employer or other coverage provider made reasonable efforts to prepare the required information for the IRS and furnish it to employees and covered individuals.

Will the IRS extend this to 2017?

The IRS doesn’t expect to extend this transition relief to 2017 reporting. Also, keep in mind that there may very well be significant changes to the ACA under Trump’s presidency.

Questions about your ACA responsibilities? Contact any member of our Healthcare Services Team.