1208Under the Patient Pro­tec­tion and Afford­able Care Act (ACA), indi­vid­u­als are required to have health insur­ance while applic­a­ble large employ­ers (ALEs) are required to offer health ben­e­fits to their full-time employ­ees. In order for the Inter­nal Rev­enue Ser­vice (IRS) to ver­i­fy that (1) indi­vid­u­als have the required min­i­mum essen­tial cov­er­age, (2) indi­vid­u­als who request pre­mi­um tax cred­its are enti­tled to them, and (3) ALEs are meet­ing their shared respon­si­bil­i­ty (play or pay) oblig­a­tions, employ­ers with 50 or more full-time or full-time equiv­a­lent employ­ees and insur­ers will be required to report on the health cov­er­age they offer. Final instruc­tions for the 1094‑B and 1095‑B and the 1094‑C and 1095‑C forms were released in Sep­tem­ber 2016, as were the final forms for 1094‑B, 1095‑B, 1094‑C, and 1095‑C. The report­ing require­ments are in Sec­tions 6055 and 6056 of the ACA.

Report­ing was first due in 2016, based on cov­er­age in 2015. Report­ing in 2017 will be based on cov­er­age in 2016. All report­ing will be for the cal­en­dar year, even for non-cal­en­dar year plans.

On Novem­ber 18, 2016, the IRS issued Notice 2016–70, delay­ing the report­ing dead­lines in 2017 for the 1095‑B and 1095‑C forms to indi­vid­u­als. There is no delay for the 1094‑C and 1094‑B forms, or for forms due to the IRS.

Orig­i­nal Deadlines Delayed Dead­lines
DUE TO THE IRS
The 1094‑C, 1095‑C, 1094‑B, and 1085‑B forms were orig­i­nal­ly due to the IRS by Feb­ru­ary 28, if fil­ing on paper, or March 31, if fil­ing electronically		 Dead­line to the IRS for all forms remains the same.
DUE TO EMPLOYEES
The 1095‑C form was due to employ­ees by Jan­u­ary 31 of the year fol­low­ing the year to which the Form 1095‑C relates.		 DUE TO EMPLOYEES
The 1095‑C form is now due to employ­ees by March 2, 2017.
DUE TO INDIVIDUALS AND EMPLOYEES
The 1095‑B form was due to the indi­vid­ual iden­ti­fied as the “respon­si­ble indi­vid­ual” on the form by Jan­u­ary 31.		 DUE TO INDIVIDUALS AND EMPLOYEES
The 1095‑B form is now due to the indi­vid­ual iden­ti­fied as the “respon­si­ble indi­vid­ual” on the form by March 2, 2017.

 

For infor­ma­tion on the exten­sion process as well as the impact on indi­vid­ual tax­pay­ers, view UBA’s ACA Advi­sor, “IRS Delay in 6055 and 6056 Report­ing for 2017”.

 

By Danielle Capil­la, Orig­i­nal­ly pub­lished by Unit­ed Ben­e­fit Advisors