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IRS extends deadlines for Affordable Care Act reporting

January 4, 2016
The Internal Revenue Service on Dec. 28 extended reporting deadlines for four forms related to the Affordable Care Act, for applicable large employers — generally those with 50 or more full-time employees and equivalents.
The deadline for providing to employees Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, has been extended from Feb. 1 to March 31, 2016. The deadline for health care providers to file the corresponding Form 1095-B also has been expanded to March 31.
Employers also must transmit to the IRS copies of the Form 1095-Cs that they provided to their employees via Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information. The time for filing Form 1094-C is extended from Feb. 29 to May 31, 2016 for non-electronic filers and from March 31 to June 30, 2016 for electronic filers. An identical extension was granted to health plan providers to transmit their Form 1095-Bs to the IRS via Form 1094-B.
Employers and other coverage providers who fail to meet these extended due dates are subject to the penalties under Code Sec. 6722 or 6721 for failure to timely furnish and file. In view of the extensions provided, the provisions regarding automatic and permissive extensions of time for filing information returns and permissive extensions for furnishing statements will not apply to the extended due dates. 
However, the IRS will consider the extent to which an employer or other coverage provider files and furnishes the statements when determining whether to abate penalties for reasonable cause. It also will consider whether reasonable efforts have been made to prepare for reporting the required information and the extent to which the employer or other coverage provider is taking steps to ensure it is able to comply with these requirements for 2016.