The IRS has extended the due dates for the 2015 information reporting requirements (Notice 2016-04). This relates to information reporting requirements under the Affordable Care Act (ACA)—both furnishing to individuals and filing with IRS—for insurers, self-insuring employers, and certain other providers of minimum essential coverage under Code Sec. 6055, and the information reporting requirements for applicable large employers (ALEs) under Code Sec. 6056. Guidance is also provided to individuals who, as a result of these extensions, might not receive a Form 1095-B or Form 1095-C by the time they file their 2015 tax returns.
The extended due dates are as follows:
- For furnishing to individuals the 2015 Form 1095-B and the 2015 Form 1095-C: from Feb. 1, 2016, to Mar. 31, 2016, and
- For filing with IRS the 2015 Form 1094-B, the 2015 Form 1095-B, the 2015 Form 1094-C, and the 2015 Form 1095-C: from Feb. 29, 2016, to May 31, 2016, if not filing electronically; and from Mar. 31, 2016, to June 30, 2016, if filing electronically.
IRS notes that most individuals offered employer-provided coverage will not be affected by the extension.
Specifically, the extension will not affect: employees who enrolled in the employer-sponsored coverage or in other coverage that was not offered through the Marketplace; employees who for any other reason would not qualify for a premium tax credit (for example, an employee who qualifies for Medicare or has household income in excess of the limits); employees who enrolled in coverage through the Marketplace and received the benefit of advance payments of the premium tax credit based on a determination by the Marketplace that the employee’s offer of employer-sponsored coverage was unaffordable; or employees who did not enroll in any coverage.
Because, as a result of the extension, individuals may not have received this information before they file their income tax returns, for 2015 only, individuals who rely upon other information received from their coverage providers about their coverage for purposes of filing their returns need not amend their returns once they receive the Form 1095-B or Form 1095-C or any corrections. Individuals need not send this information to the Service when filing their returns but should keep it with their tax records.