2016 Affordable Care Act Reporting Deadlines Extended

2016 Affordable Care Act Reporting Deadlines Extended

KEEPING YOU INFORMED…

As we previously advised you in our January 20 and August 31, 2015 client memos (copies attached), the Patient Protection and Affordable Care Act (“the ACA”) requires certain large employers to annually report whether and what health insurance coverage has been offered to full-time employees. The ACA also requires health care providers to report certain information about individuals who are covered by the plan.

The IRS recently announced transition relief that extends the filing deadlines for forms filed in 2016. The changes are set forth in the chart below.

Reporting RequirementPrevious Deadline for 2016New Deadline for 2016
Provide Form 1095-B to responsible individuals and Form 1095-C to employeesFebruary 1, 2016March 31, 2016
File by Mail Forms 1094-B and 1094-C with the IRSFebruary 29, 2016May 31, 2016
File Electronically Forms 1094-B and 1094-C with the IRSMarch 31, 2016June 30, 2016

Due to these extended deadlines, the rules regarding automatic and permissive extensions will not apply for forms filed in 2016. Those rules, and the original deadlines, will apply for forms filed beginning in 2017.

Please contact us if you have any questions about your ACA reporting obligations.

THIS MEMORANDUM IS MEANT TO ASSIST IN GENERAL UNDERSTANDING OF THE CURRENT LAW. IT IS NOT TO BE REGARDED AS LEGAL ADVICE. THOSE WITH PARTICULAR QUESTIONS SHOULD SEEK THE ADVICE OF COUNSEL.

© Lamb & Barnosky, LLP 2015

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