In what has seemingly become the new normal for the IRS when working with the Affordable Care Act, another deadline has been extended. This time, on December 28, 2015, the IRS extended the deadline for ACA reporting with Notice 2016-04.
The new deadlines are as follows:
- 1095-B and 1095-C must be delivered to employees by March 31, 2016
- 1094 B & C and 1095-B & C, if delivered by paper to the IRS by May 31, 2016
- 1094 B & C and 1095-B & C, if delivered electronically to the IRS by June 30, 2016
This extension applies to whomever is responsible for reporting under Section 6055 and 6056 of the IRS Code (employers, insurers, self-insured, etc.). Further, the IRS has indicated that they will not allow any further deadline extensions. If you are struggling to meet the new deadline, our best advice is for you to complete the forms as soon as possible and get them into the IRS as this good faith effort may result in the IRS abatement of the penalties – assuming you can provide a reasonable explanation as to why the deadline was missed.
Also, keep in mind that while the IRS has extended your deadline, they have not extended the deadline for any of your employees that may need some of this information contained on forms 1095 – b and 1094 – C when filing their own taxes for 2015.
SBAM’s endorsed payroll and benefits administration partner, Benepay Technologies, can help. If your company needs help in preparing the IRS Forms, call SBAM’s Kellie Neirynck at 800.362.5461 and she can connect you with the right person at Benepay. Benepay has re-opened its ACA Reporting Service for SBAM members until January 31, 2016 for the 2015 reporting period. They are also accepting 2016 business now.
A special note for SBAM members enrolled with Blue Cross Blue Shield of Michigan and Blue Care Network:
Blue Cross Blue Shield of Michigan and Blue Care Network will report information for their underwritten groups to the IRS (Forms 1094-B Transmittal Form and 1095-B) and also issue statements (Form 1095-B) on coverage to their enrolled subscribers. It is expected that these statements will be mailed in the late January to early February timeframe. If your group is self-funded, the plan sponsor must report this information within the above timeframe.