November 28, 2016 2017 Affordable Care Act Reporting Deadlines Extended
KEEPING YOU INFORMED…
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 and employers providing self-insured coverage to report certain information about individuals who are covered by the plan.
The IRS recently announced transition relief that extends by 30 days the filing deadlines for Forms 1095-B and 1095-C filed in 2017. The deadlines are set forth in the chart below.
| Reporting Requirement | Previous Deadline for 2017 | New Deadline for 2017 |
| Provide Form 1095-B to responsible individuals and Form 1095-C to employees | January 31, 2017 | March 2, 2017 |
| File by Mail Forms 1094-B and 1094-C with the IRS | February 28, 2017 | No change |
| File Electronically Forms 1094-B and 1094-C with the IRS | March 2, 2017 | No change |
Due to the deadline change, the rules regarding automatic extensions will not apply to Forms 1095-B and 1095-C filed in 2017, and the IRS will not formally respond to any request for an automatic 30-day extension. The automatic extension rules will continue to apply to the deadlines for Forms 1094-B and 1094-C filed in 2017, and the IRS will respond to requests for an extension.
In addition, the IRS extended the good faith transition relief for reporting 2016 information; i.e., the IRS will not impose penalties on entities demonstrating a good faith effort to comply with the reporting requirements. This relief only applies to incorrect or incomplete forms. It does not apply to an entity that fails to file one or more forms or fails to timely do so.
If you have any questions about your ACA reporting obligations, please contact Alyson Mathews at am@lambbarnosky.com or 631-694-2300.
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 2016