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Today, March 31 is theIRS deadline for employers to provide electronic filings of forms 1094-C and 1095-C to the IRS for the 2019 tax year as required by the ACA’s Employer Mandate. Did you submit them on time?
Under the ACA’s Employer Mandate, Applicable Large Employers (ALEs) organizations with 50 or more full-time employees and full-time equivalent employees) are required to offer Minimum Essential Coverage (MEC) to at least 95% of their full-time workforce (and their dependents) whereby such coverage meets Minimum Value (MV) and is Affordable for the employee or be subject to Internal Revenue Code (IRC) Section 4980H penalties.
Every year ALE’s are required to file information returns with the IRS to identify whether they offered health coverage to their full-time employees (and their dependents) and information about the type of coverage offered. Employers must provide this information to the IRS via Forms 1094-C and 1095-C. ALEs must also provide a copy of Form 1095-C to their full-time employees, including to any person employed full-time for one or more months of the reporting year.
In the event you were not able to meet the electronic filing deadline, and didn’t paper file, you may be able to file for an extension without being assessed a late penalty.
Employers can file for a 30-day auto extension for their ACA information filings via IRS Form 8809, Application for Extension of Time To File Information Returns. Employers should note that this form is an application, and your extension may be denied. Be prepared to present a case as to why your organization needs an extension.
As we’ve previously discussed, the Affordable Care Act Information Returns (AIRS) portal goes offline for scheduled and unscheduled maintenance. It did that a number of times leading up to the electronic filing deadline, so applying for an extension this time around may be in your favor.
The IRS is currently issuing penalties to employers that fail to meet this deadline as well as other deadlines under IRC 6721/6722 in Letter 5005-A/Form 886-A. Both types of penalty assessments can be in the millions of dollars, even for smaller ALEs.
If your organization needs assistance in filing for an extension in order to meet the electronic filing deadline, contact us to learn about ACA Complete. If you’re unsure of the accuracy of your ACA filings, consider undergoing an ACA Penalty Risk Assessment to learn their penalty exposure.