ACA Reporting Deadline Extended

December 22, 2017 – The Internal Revenue Service (IRS) has issued Notice 2018-06 to extend the deadline for furnishing forms under sections 6055 and 6056 for 2017 to March 2, 2018, from January 31, 2018. The notice also extends the good-faith transition relief from penalties related to 2017 information reporting under Sections 6055 and 6056. There is no request or other documentation required to take advantage of the extended deadline.

Notice 2018-06 does not extend the due date for filing forms with the IRS for 2017. The deadline for filing with the IRS under Sections 6055 and 6056 remains February 28, 2018, or April 2, 2018, if filing electronically.

Section 6055 and 6056 Reporting

Sections 6055 and 6056 were added to the Internal Revenue Code (Code) by the Affordable Care Act (ACA).

• Section 6055 applies to providers of minimum essential coverage (MEC), such as health insurance issuers and employers with self-insured health plans. These entities will generally use Forms 1094-B and 1095-B to report information about the coverage they provided during the previous year.
• Section 6056 applies to applicable large employers (ALEs)­­—generally, those employers with 50 or more full-time employees, including full-time equivalents, in the previous year. ALEs will use Forms 1094-C and 1095-C to report information relating to the health coverage that they offer (or do not offer) to their full-time employees.

Extended Furnishing Deadline

The IRS has again determined that some employers, insurers and other providers of MEC need additional time to gather and analyze the information and prepare the 2017 Forms 1095-B and 1095-C to be furnished to individuals. Therefore, Notice 2018-06 provides an additional 30 days for furnishing the 2017 Form 1095-B and Form 1095-C, extending the due date from Jan. 31, 2018, to March 2, 2018.

Despite the delay, employers and other coverage providers are encouraged to furnish 2017 statements to individuals as soon as they are able.

 

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This regulatory update is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.