IRS Extends Affordable Care Act Filing Deadlines

The IRS has extended the due dates for some of the 2015 reporting required under the Affordable Care Act.

The due date for furnishing to individuals their copies of 2015 Forms 1095-B (Health Coverage) and 1095-C (Employer-Provided Health Insurance Offer and Coverage) has been extended from February 1, 2016, to March 31, 2016. The due date for filing Forms 1095 to the IRS—along with their accompanying Form 1094 transmittal forms—has been extended from February 29, 2016, to May 31, 2016, if not filing electronically. If filing electronically, the due date is extended from March 31, 2016, to June 30, 2016.

The IRS notice containing these extensions (Notice 2016-4) applies to insurers, self-insured employers, and certain other providers of minimum essential coverage that are required to file Forms 1094-B or 1095-B. It also applies to applicable large employers (ALEs) that are required to file Forms 1094-C or 1095-C. While the IRS is prepared to accept the filings of the Forms 1094 and 1095 starting in January, it determined that employers, insurers, and other providers of minimum essential coverage need additional time to gather, analyze, and report the required information.

How Will Individual Filers Be Affected?

Individuals will use the information provided on Forms 1095-B and 1095-C to confirm that they had minimum essential coverage in 2015. Knowing whether individual taxpayers and their dependents have minimum essential coverage is necessary to determine their eligibility for premium tax credits (for coverage acquired via the Marketplace) as well as the extent to which those taxpayers are subject to the individual mandate penalty for not having minimum essential coverage.

The IRS stated that, for 2015 tax returns only, individuals can rely on other information they receive from their insurance provider or employer to determine which months during 2015 they had minimum essential coverage. It isn’t necessary for individuals to wait until they receive Forms 1095-B and 1095-C to file their individual income tax returns. Any Forms 1095-B or 1095-C individuals receive after filing their individual tax returns should simply be retained with their tax return records. They won’t need to file amended income tax returns for Forms 1095-B and 1095-C received after their tax return has been filed.

Notice 2016-4 doesn’t state whether the IRS will follow up with individual filers if the reporting on the individual income tax return differs from what’s ultimately reported on Forms 1095-B and 1095-C.

Additional Considerations

Note that these extensions apply only to the B and C series of Forms 1094 and 1095. Forms 1095-A, which are filed by state and federal health insurance marketplaces, aren’t eligible for the extended due dates. Individuals who obtained their 2015 health insurance coverage through a health insurance marketplace should wait to file their individual income tax returns until all Forms 1095-A have been received.

For additional information on the filing requirements for Forms 1094 and 1095, see our October 2015 Alert: Prepare Data Now for Looming ACA Information Reporting Deadlines. Or reach out to your Moss Adams professional for additional insight relevant to your particular tax and filing situation.