IRS Extends 2015 ACA Reporting Deadlines for Employers (Forms 1095-B, 1095-C)

  • Posted by: J. Kent Gervasini |
  • 1/9/16 |
  • 3:02 PM
IRS Extends 2015 ACA Reporting Deadlines for Employers (Forms 1095-B, 1095-C)

Extension gives employers and software developers additional time to finalize critical programming and testing.

On Dec. 28, 2015 the IRS issued Notice 2016-4 extending the due dates for new health care information reporting forms due in 2016. Insurers, self-insuring employers, other coverage providers, and applicable large employers (ALEs) now have additional time to provide health coverage information for 2015 to individual taxpayers and the IRS.

IRS Notice 2016-4 officially extends the deadlines to employers for providing "B" and "C" forms to individuals and to the IRS as required by the Affordable Care Act (ACA). The notice also provides individuals guidance on how this impacts their personal tax return.

What are the New Healthcare (ACA) Reporting Tax Forms; What do They Look Like? 
The new forms are:

  • Form 1095-A, Health Insurance Marketplace Statement. The Health Insurance Marketplace (Marketplace) sends this form to individuals who enrolled in coverage there, with information about the coverage, who was covered, and when.
  • Form 1095-B, Health Coverage. Health insurance providers (for example, health insurance companies) send this form to individuals they cover, with information about who was covered and when.
  • Form 1095-C, Employer-Provided Health Insurance Offer and Coverage. Certain employers send this form to certain employees, with information about what coverage the employer offered. Employers that offer health coverage referred to as “self-insured coverage” send this form to individuals they cover, with information about who was covered and when.

ALERT - New 2015 ACA Information Reporting Deadlines

To Forms Original Due Date New Deadline
Individuals     1095-B                    or 1095-C Monday, February 1, 2016 Thursday, March 31, 2016
 IRS 1095-B
Monday, February 29, 2016 (or Thursday, March 31, 2016 if filing electronically)

Tuesday, May 31, 2016 (or Thursday, June 30, 2016, if filing electronically)

Guidance to Employers - Continue Good Faith Efforts to Meet Original Filing Deadline
While insurers and employers are encouraged to file as soon as possible, this will provide additional time for software developers and employers to finalize programming and testing. In light of this announcement, any employers that had requested an extension will not receive a response from the IRS.

However, although many will breathe a sigh of relief that the deadline has been extended, employers should not get too comfortable.  The IRS states that in light of the extended deadlines, no requests will be granted for further extensions of time to file.The extended deadlines are fixed for every employer. Employers should continue their good faith efforts to meet the filing requirements, as failure to comply with these extended due dates will result in the imposition of penalties.

Guidance to Individuals – For 2015 Only
Due to these extensions, some individual taxpayers may not receive a Form 1095-B or Form 1095-C by the time they are ready to file their 2015 tax return. While the information on these forms may assist in preparing a return, they are not required. Like last year, taxpayers can prepare and file their returns using other information about their health insurance. Individual taxpayers will generally not be affected by this extension, should file their tax returns as they normally would and do not have to wait for their Form 1095-B or 1095-C in order to file.

"For 2015 only, individuals who rely upon other information received from employers" or "from coverage providers ... when filing their personal income tax returns need not amend their returns once they receive" the necessary form(s). "Individuals need not send this information to the Service when filing their returns but should keep it with their tax records."

Questions and Answers for New Information Reporting Forms
The IRS has posted a set of questions and answers that introduce the new Forms 1095-B and 1095-C. The questions and answers explain who should expect to receive the forms, how they can be used, and how to file with or without the forms.


The information above does not constitute professional               legal, insurance or tax advice.
Employers, individuals and corporate entities should consult their business professional with additional questions, or for guidance and more information.

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