The IRS has just issued Notice 2016-4, which provides a two month extension for ACA reporting by employers and insurance carriers. The notice recognizes that additional time is needed for employers, carriers, and vendors to comply with the complex requirements and new systems.

The employer’s deadline for reporting offers of medical coverage (§6056) to full-time employees on Forms 1095-C is now delayed to March 31, 2016. The deadline for filing transmittal Form 1094-C (with copies of the Forms 1095-C) to the IRS is delayed to May 31, 2016 (by paper) and to June 30, 2016 (electronically). Employees who had Marketplace coverage in 2015 may use the information on Forms 1095-C to determine eligibility for a tax credit. For employees covered by a self-insured medical plan, the Form 1095-C also shows the months enrolled in medical coverage.

The deadline for reporting by insurance carriers (§6055) to covered individuals on Forms 1095-B is now delayed to March 31, 2016.

For individuals who need this information to confirm which months they had medical coverage for purposes of completing their 2015 tax returns, the notice states that they can rely on other information received from their health coverage provider. Note that neither the Form 1095-C nor 1095-B must be filed with tax returns, but should be kept with tax records.

During this much-needed extension of time, Keller account teams will continue working with our clients and their vendors to finalize the reporting forms.