Delayed Filing Date for 2015 Forms 1094 & 1095

On December 28, the IRS issued Notice 2016-4, in which it delayed the deadline for filing 2015 Forms 1094 with the IRS and providing 2015 Forms 1095 to individuals. This will likely come as a great relief to many employers who have been figuring out how to complete these new forms, which are required to comply with new health care information reporting mandated by the Affordable Care Act.

Under this new information reporting requirement (which first became effective for the 2015 calendar year), any “Applicable Large Employer” who had more than 50 full-time employee equivalents in 2014 is required to report whether it offered medical coverage to its full-time employees in 2015.

The original due date for reporting 2015 offers of coverage to full-time employees through a Form 1095-C was February 1, 2016, but that date has now been extended to March 31, 2016.

The original due date for reporting 2015 offers of coverage to the IRS through a Form 1094-C was February 29, 2016 (if not filing electronically) and March 31, 2016 (if filing electronically). The IRS has now automatically delayed those due dates by 3 months, so the new deadlines are May 31, 2016 (if not filing electronically) and June 30, 2016 (if filing electronically, which is required for entities filing 250 or more Forms 1095-C).

Please note that because these extensions are automatic for all filers, the IRS has clarified that it will not grant any additional extensions of time to the delayed due dates.

Today’s post was contributed by Cynthia Y. Lee

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