IRS Extends Deadlines for 2015 Affordable Care Act Information Reporting
On December 28, 2015, the Internal Revenue Service ("IRS") issued Notice 2016-4
which extends the deadline for employers, insurers, and other parties to complete information reporting under Internal Revenue Code ("Code") Sections 6055 and 6056. In general, reporting entities have an additional two months to provide statements to individuals and an additional three months to file returns with the IRS.
This reporting is required by the Patient Protection and Affordable Care Act ("PPACA") which added Code Sections 6055 and 6056. Code Section 6055 requires insurers, employers sponsoring self‑insured health plans, and other entities providing minimum essential health coverage to report certain information to the IRS and to furnish statements to individuals about the provided coverage. Code Section 6056 requires applicable large employers to report certain information to the IRS and to furnish statements to their full-time employees about the health insurance coverage the employer offered. This reporting allows the IRS to monitor PPACA's individual mandate, employer penalty provisions, and premium tax credits (or "exchange subsidies"), and to impose penalties where appropriate.
Under the extended deadlines, reporting entities have until March 31, 2016
, to furnish individuals with the 2015 Form 1095-B, Health Coverage
, or the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage
. These forms were originally required to be furnished by February 1. In addition, reporting entities have until May 31, 2016
(extended from February 29), if filing by paper, and until June 30, 2016
(extended from March 31), if filing electronically, to file with the IRS: (i) the 2015 Form 1094-B, Transmittal of Health Coverage Information Returns
; (ii) the 2015 Form 1095-B, Health Coverage
; (iii) the 2015 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
; and (iv) the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage
Employers and reporting entities will certainly welcome these extensions. Reporting entities should take care to use the additional time to ensure that they have complete data in order to provide accurate reporting to individuals and to the IRS. For more information about reporting under Code Section 6055 or 6056 and employers' obligations under the PPACA, please contact Christopher S. Sears
, Tara Schulstad Sciscoe
, Mary Beth Braitman
, Melissa Proffitt
, Sarah K. Funke
or the Ice Miller Employee Benefits
attorney with whom you work.
This publication is intended for general information purposes only and does not and is not intended to constitute legal advice. The reader should consult with legal counsel to determine how laws or decisions discussed herein apply to the reader’s specific circumstances.