Extension Form 1095-B or Form 1095-C

The U.S. Department of the Treasury and IRS released final rules on ACA reporting. The extension of the filing deadline for employers is a welcome reprieve from the new reporting requirements. Fortunately, the majority of individuals will not be affected by the delay of the receipt of their 1095 form. Employees enrolled in an eligible employer-sponsored plan are not eligible for premium tax credits for any month the employee is eligible for coverage that provides minimum value (MV) and is affordable. The 1095 data is collected at the Health Insurance Marketplace prior to the purchase of insurance coverage.

Employees who enrolled in coverage through the Marketplace and file their tax returns prior to receiving their MEC status simply need to keep the MEC information with their tax records. They do not do not need to file an amended return or send this information to the IRS.

Employers must meet the extended due dates. Failure to do so will subject the employer to penalties outlined in IRS Code Sections 6722 and 6721. The IRS may give leeway of penalties for reasonable cause. The filing extensions are only for 2015 and do not apply to any other calendar year. Please see Notice 2016-4.

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