IRS Extends First Filings of Forms 1094/1095

Under the ACA Sections 6055 and 6056, all Applicable Large Employers (ALEs) [that is, employers with 50 or more full-time employees plus full-time equivalents] as well as all employers of any size whose health plan(s) were self-funded were to begin distributing IRS Form 1095-C to employees by February 1, 2016 (since January 31st was a Sunday).  Those same employers were to file the IRS Form 1094-C along with a copy of each individual 1095-C with the IRS by no later than February 29, 2016 if filing by paper, or by March 31, 2016 if filing electronically.  Similarly, for non-ALEs with fully insured plans, the insurance carriers were responsible for preparing and distributing 1095-B forms to employees and filing the 1094-B along with a copy of the individual 1095-Bs on the same timeline.  Those deadlines are now extended only for the first 2015 filings of those forms.

IRS Notice 2016-4 now provides an automatic extension for the filing of those forms.  Instead of February 1st, 1095-B and 1095-C forms must now be furnished to employees by no later than March 31, 2016, and the IRS filing of the 1094-B and 1094-C (with the accompanying individual forms) must be made by no later than May 31, 2016 if filing non-electronically, or by no later than June 30, 2016 if filing electronically.

This is reasonably good news for those employers who have waited too long before examining the extent of the needed filings, and for those whose payroll and HRIS systems are lacking in the ability to properly code the 1095-C forms.

Posted on December 28, 2015 by Gary B. Kushner, SPHR, CBP, President and CEO

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