December 05, 2018 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 IRS filing deadlines for 2018 Forms 1095-B and 1095-C. The deadlines are set forth in the chart below.
| Reporting Requirement | Previous Deadline | New Deadline |
| Provide Form 1095-B to responsible individuals and Form 1095-C to employees | January 31, 2019 | March 4, 2019 |
| File by Mail Forms 1094-B and 1094-C with the IRS | February 28, 2019 | No change |
| File Electronically Forms 1094-B and 1094-C with the IRS | April 1, 2019 | No change |
The Notice extends the due date for furnishing the 2018 Forms 1095-B and 1095-C. Accordingly, the rules allowing the IRS to grant an automatic extension of time of up to 30 days to furnish Forms 1095-B and 1095-C will not apply to the extended due date.
Filers of Forms 1095-B, 1094-C, and 1095-C may continue to receive an automatic 30-day extension of time to submit these forms to the IRS by submitting Form 8809, Application for Extension of Time to File Information Returns, on or before the due date for filing those forms.
In addition, the IRS extended the good faith transition relief for reporting 2018 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 REGARCED AS LEGAL ADVICE. THOSE WITH PARTICULAR QUESTIONS SHOULD SEEK THE ADVICE OF COUNSEL.
©Lamb & Barnosky, LLP 2018