For many employers, this will be the first year of reporting health coverage to the IRS for its employees. Under the Affordable Care Act, applicable large employers (ALE) with 50 or more full-time employees and/or equivalents must report this information for the 2015 tax year. Traditionally, such documentation holds the same deadlines as W-2 reporting. However, considering this is a fairly new practice under the Affordable Care Act, the IRS provided extensions for reporting health coverage forms for 2015.
Forms 1095-B and 1095-C—which include minimal essential coverage and ALE health coverage, respectively—must be received by employees no later than March 31, 2016. This is a two-month extension from the traditional January 31st deadline. Likewise, the paper filings of Forms 1094-B, 1095-B and C must be filed with the IRS by that sameMarch 31 deadline (previously February 28), unless electronically filed, which then carries a June 30, 2016 deadline (previously March 31). Please note that these extended dates were specifically provided for 2015, and may not apply next tax year.
Employers may want to inform their employees of these extensions allowing for delay in supplying documentation. While employees are free to file their tax returns without receipt of Form 1095-C, employers should consider sending out a reminder of this information. If your forms are generated by a third party, be sure to conduct checks on the document information, as margins of error are common. The good news is the IRS is aware of first-year issues and possible errors to work out with health care reportIRS has announced that a good faith exception exists. However, how broadly such “good faith” will be interpreted by the IRS is not certain. Be mindful of those dates and have your filings in as soon as possible.
