Deadlines for Information Reporting Required by the Affordable Care Act Extended

Internal Revenue Code sections 6055 and 6056 were added to the Internal Revenue Code by the Affordable Care Act and impose certain reporting requirements on minimum essential coverage providers and applicable large employers. The IRS recently issued Notice 2016-4, extending the due dates for the information reporting required by sections 6055 and 6056 for the 2015 calendar year. The extensions provided by the IRS in Notice 2016-4 are automatic and apply to any taxpayer required to file information returns and statements under either section.

Section 6055: Provider Reporting of Minimum Essential Coverage

Section 6055 requires minimum essential coverage providers to issue covered individuals annual statements detailing the coverage provided during the calendar year on or before January 31 of the following year. Additionally, section 6055 requires these same providers to file information returns with the IRS on or before February 28 of the following year (March 31 if filed electronically). Minimum essential coverage providers satisfy their obligation to individuals covered during the calendar year by issuing each covered individual a Form 1095-B. Minimum essential coverage providers satisfy their obligations to the IRS by filing with the IRS Form 1094-B along with copies of the Forms 1095-B.¹  Minimum essential coverage providers satisfy their obligations to the IRS by filing with the IRS Form 1094-B along with copies of the Forms 1095-B.

Section 6056: Applicable Large Employer Reporting of Health Insurance Offered
Section 6056 requires applicable large employers to issue employees annual statements detailing the health insurance coverage offered to the employees and their dependents during the calendar year on or before January 31 of the following year. Additionally, section 6056 requires applicable large employers to file information returns with the IRS on or before February 28 of the following year (March 31 if filed electronically). Applicable large employers satisfy their obligations to their employees by issuing each employee a Form 1095-C. Applicable large employers satisfy their obligations to the IRS by filing with the IRS Form 1094-C along with copies of the Forms 1095-C.

Extended Deadlines for 2015 Calendar Year Reporting

For the 2015 calendar year reporting, Notice 2016-4 extends the due date to March 31, 2016 for providers of minimum essential coverage to issue Forms 1095-B to covered individuals and extends the due date to May 31, 2016 (June 30, 2016 if filed electronically) for providers to file their Forms 1094-B and 1095-B with the IRS. Similarly, Notice 2016-4 extends the due date to March 31, 2016 for applicable large employers to issue Forms 1095-C to employees and extends the due date to May 31, 2016 (June 30, 2016 if filing electronically) for applicable large employers to file their Forms 1094-C and 1095-C with the IRS.

Extensions Requested Under the Preambles to Final Regulations Will Not Be Granted

Notice 2016-4 makes clear that the IRS will not grant formal requests for extensions made pursuant to the preambles to final regulations under sections 6055 or 6056. In the preambles to final regulations under sections 6055 and 6056, the IRS provides taxpayers the opportunity to request extensions of time to furnish and file statements required for the 2015 calendar year. However, the extensions available were for shorter 30-day periods and, in the case of an extension of time to furnish Forms 1095-B and Forms 1095-C to individuals, the extensions were not automatic. Thus, the extended due dates provided by Notice 2016-4 are more generous and automatic; therefore, the IRS will not grant any extensions made pursuant to the preambles.

The 2016 reporting year promises to be challenging for taxpayers and their advisors attempting to comply with the Affordable Care Act. If you have questions regarding the requirements of the Affordable Care Act, please contact Aaron Borden at (214) 749-2402 or aborden@meadowscollier.com.

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¹Applicable large employers, who are also providers of minimum essential coverage, are allowed to include the information required by section 6055 on Forms 1095-C in conjunction with the information reporting required under section 6056. Under this alternative, instead of issuing each employee a Form 1095-B and a Form 1095-C, the applicable large employers include the information required by section 6055 in Part III of Form 1095-C.