Deadline Extended for Furnishing Forms 1095-C to Employees
Under the Affordable Care Act reporting requirements, applicable large employers and employers that offer self-insured health care coverage to their employees are required to furnish Forms 1095-C to their employees by January 31, 2017. With IRS Notice 2016-70, the IRS extends the deadline for furnishing these statements to employees until March 2, 2017. This is similar to relief provided by the IRS last year. This is an automatic extension, which requires no additional paperwork. No additional extensions will be provided by the IRS. Insurance providers, who were required to provide Forms 1095-B to covered individuals, received the same relief under IRS Notice 2016-70.
Similar to last year, employees who need to report whether they maintained minimum essential coverage during 2016 may rely on other information provided by their employers or insurance carriers if they choose to file their personal tax returns prior to the receipt of the applicable statements.
Notice 2016-70 does not extend the deadline for filing Forms 1094 or 1095 series with the IRS. The deadline for furnishing statements to the IRS remains February 28, 2017, if filed by paper, or March 31, 2017, if filed electronically. Employers can still file Form 8809 to receive an automatic 30 day extension or an additional 30 day extension for certain cases of hardship.
Similar to last year, the IRS has extended good faith transition relief to employers for filing incorrect statements with the IRS or providing incorrect statements to employees, as long as the statements are timely furnished or filed. This should be welcome news for employers, since the penalties are generally $260 for each incorrect statement furnished or filed. To receive this good faith transition relief, employers must make a reasonable effort when furnishing statements either to their employees or the IRS. Similar relief is provided for insurance carriers that are required to furnish statements to the IRS and covered individuals. Filing statements after the deadline will only be excused by the IRS if the failure to file is outside the employer’s control.