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IRS Extends ACA Reporting Deadlines

By: Jill E. Hall and Lenna R. Chambers
December 29, 2015

On December 28, 2015, the Internal Revenue Service issued Notice 2016-4, which extends the due dates for furnishing and filing the new Affordable Care Act (ACA) reporting forms. Beginning in 2016, large employers (those with 50 or more full-time equivalent employees) must furnish to their full-time employees and file with the IRS certain forms that report offers of health coverage made to employees in the previous calendar year. Employers have an additional two months to provide employees with Forms 1095-C and an additional three months to file the returns, along with Form 1094-C, with the IRS. Forms 1095-C are now due to employees by March 31, 2016. Form 1094-C and the accompanying 1095-C returns are due to the IRS by June 30, 2016 if filing electronically, or by May 31 if not filing electronically.* It is important to note that additional extensions previously available to employers will not be permitted as a result of this latest relief. This is a welcome extension for large employers grappling with the volumes of information necessary to satisfy the ACA’s reporting requirements.

* Employers filing 250 or more returns must file electronically.