The IRS announced that the deadline for employers to furnish 2019 Forms 1095-C to employees has been extended from January 31 to March 2, 2020. The extension also applies to Forms 1095-B, issued by carriers or small self-insured employers. The deadline for filing both forms to the IRS is still February 28, or March 31, 2020 if filing electronically.

Additionally, IRS Notice 2019-63 states that since there is no longer a taxpayer penalty for not having medical coverage:

  • Forms 1095-B issued by carriers or small self-insured employers, showing medical coverage of each enrolled family member, do not need to be furnished to employees.
  • Forms 1095-C issued by large self-insured employers, showing medical coverage of each enrolled family member in Part III, do not need to be furnished to part-time or former employees for whom an offer of coverage was not required for any month in 2019.
  • If not furnished per the above, the reporting entity (carrier or employer) must post a notice prominently on its website that the employee or other family member can request a copy and provide the copy within 30 days of a request.
  • The Treasury and IRS are requesting comments on how the medical coverage reporting requirement should change for future years.

For employers subject to the employer shared responsibility mandate, the Forms 1095-C must still be completed, furnished to full-time employees, and transmitted to the IRS.

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