ACA Employer Reporting 2015: IRS Extends Due Dates | DCR Workforce Blog

ACA Employer Reporting 2015: IRS Extends Due Dates

2015 aca reporting

Whoever expected the Internal Revenue Service (IRS) to come bearing New Year gifts!? It goes to show that miracles do happen, sometimes!

On Dec 28, 2015, the IRS informed employers that the due dates established for 2015 information reporting requirements under the Affordable Care Act (ACA) have been extended. Now, employers can enjoy an extra two months to furnish forms to individuals and another three months before they file the forms for the IRS.

Background Information on ACA Reporting Requirements:

Let us look at what the existing rule said and what the extended new dates are:

  • Employers, who employ 50 or more full time and full time equivalent employees in 2014, are required to furnish information about the health coverage they offered (or did not offer) to certain employees in 2015. Furnish Form 1095-C (from February 1, 2016 to March 1, 2016) to the employee and file copies with transmittal form 1094-C with the IRS.
  • Furnish information about all those who enrolled in a self-funded (self-insured) health plan which is provided by the employer to provide minimal essential coverage in 2015, using 1095-B to primary enrollees and use 1094-B for the transmittal form.
  • The deadline for filing the 2015 Forms 1095-C and 1094-C (also known as the transmittal Form), or Forms 1095-B and 1094-B (the transmittal Form), if applicable, with the IRS by May 31, 2016, if filing by paper (extended from February 29, 2016) and by June 30, 2016, if filing electronically (extended from March 31, 2016).

Employers who have requested for extensions need not wait for their individual requests to be granted formally as these new dates come into force automatically. Those who are well prepared and ready to turn in their reports can go ahead and submit them. The employers, insurers and other providers of coverage who need more time to adapt and implement systems and gather, analyze and report the information can use the additional time to achieve their goals.
Let us look at some of the other assurances from the IRS to employers with regard to their efforts to meet the tenets of the Affordable Care Act.

  • There are no penalties on entities which attempted to comply with requirements in good faith and submitted reports; but filed incomplete or incorrect information.
  • Employer penalties may also be waived when failure to file on time was due to reasonable cause.
  • When employers and other coverage providers miss the extended due date, they will be subject to penalties. However, the IRS will consider the efforts they made to comply and the steps they took to ensure compliance and will waive the applicable penalties if these are considered reasonable.
  • Employers who enrolled in coverage through the marketplace but received no determination that employer-sponsored coverage was not affordable could be affected by the extension if they do not receive a 1095-C before they file their tax returns. Keeping this in mind, the IRS provides that, for 2015 only, individuals may rely on other information they receive from their employers for purposes of determining eligibility for premium tax credits when they file their returns, and will not need to file amended returns if the information they rely on turns out to be incorrect.
  • Similarly, for 2015 only, individuals who do not receive a 1095-B before filing their income tax returns may rely on other information they have received from their coverage provider assuring them that they have minimum essential coverage in filing their income tax returns; and need not file amended returns even if the information they relied on turns out to be incorrect.
  • Taxpayers who had marketplace coverage during the year and received advance premium tax credits will need to wait until they receive their 1095-A form from the marketplace before they file their 2015 tax returns.

The content on this blog is for informational purposes only and cannot be construed as specific legal advice or as a substitute for competent legal advice. They reflect the opinions of DCR Workforce and may not reflect the opinions of any individual attorney. Do contact an attorney for advice specific to your issue or problem.
Lalita is a people/project manager with extensive experience in operations, HCM and training and development across industries like banking, education, business consulting, BPO and information technology. She believes in a dynamic approach to life and learning as change is the only constant.