Wyatt Employment Law Report

ACA Reporting Deadline Extended

1 Comment

By Rachel K. Mulloy

The IRS recently released good news for employers, service providers, and others who are required to file the 1094 and 1095 series Information Return forms pursuant to the Affordable Care Act.  In Notice 2016-4, the IRS has granted additional time for filing these forms for 2015:

  • The deadline for providing individuals with Form 1095-B (Health Coverage) and Form 1095-C (Employer-Provided Health Insurance Offer and Coverage) has been extended from February 1, 2016, to March 31, 2016; and
  • The deadline for filing Form 1094-B (Transmittal of Health Coverage Information Returns), Form 1095-B (Health Coverage), Form 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns), and Form 1095-C (Employer-Provided Health Insurance Offer and Coverage) has been extended from March 31, 2016, to June 30, 2016 if filing electronically, and from February 29, 2016 to May 31, 2016, if not filing electronically.

Employers and service providers should not, however, expect any further extensions.  As the IRS explained: “In view of these extensions, the provisions regarding automatic and permissive extensions of time for filing information returns and permissive extensions of time for furnishing statements will not apply to the extended due dates. Employers or other coverage providers that do not comply with these extended due dates are subject to penalties under section 6722 or 6721 for failure to timely furnish and file. However, employers and other coverage providers that do not meet the extended due dates are still encouraged to furnish and file, and the Service will take such furnishing and filing into consideration when determining whether to abate penalties for reasonable cause . . . .”

One thought on “ACA Reporting Deadline Extended

  1. Thank you for this update. This is good news for employers.

    I do have a concern with the Transmitter Control Code that we are required to apply for in order to transmit the data to the IRS. It requires me to submit MY personal information (date of birth, social security number and MY adjusted gross income for 2013 or 2014) in order for me to get the TCC so I can input the information for my organization. I feel this is an invasion on my privacy, and not relevant to the task. I can see putting the company’s EIN and perhaps gross revenues there to get the code. I’m also okay with having my name listed as a contact if the IRS has a question.

    The IRS has told me the code is my personal code and that I can go in and edit the information for the company, but my personal information / code shouldn’t be linked to the company in this way. I am concerned about my personal liability if something doesn’t go well with this reporting and am not willing to put me or my spouse at risk in this way.

    I am currently looking for an alternative to get this done, but haven’t identified that yet.

Leave a reply. Please note that although this blog may be helpful in informing clients and others who have an interest in information privacy and security, it is not intended to be legal advice. The information on this blog also should not be relied upon to form an attorney-client relationship.

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