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The IRS extended the health coverage information reporting deadlines, giving employers and providers additional time to supply tax forms to individuals.

Navigating health reform

ACA Reporting Deadlines Extended With Good-Faith Transition Relief

  • Anita Baker
  • Karlye Broten
  • 12/21/2018

On November 29, 2018, the IRS issued Notice 2018-94, extending the Affordable Care Act (ACA) 2018 deadline for providing individuals Form 1095-B, Health Coverage, and 1095-C, Employer-Provided Health Insurance Offer and Coverage. The notice also offers similar good-faith effort for 2018 as was available for 2017. This is an automatic 30-day extension from the original due date of January 31, 2019, and employers and providers don’t have to request it. Take note that the recent ruling does not impact reporting requirements for the 2018 tax year.

Reporting requirement 2019 deadline
Filing Forms 1095-B and 1095-C in paper format to the IRS February 28
Providing individuals Form 1095-B and/or 1095-C March 4
Filing Forms 1095-B and 1095-C in electronic format to the IRS April 1

Internal Revenue Code Section 6056 requires applicable large employers (ALEs) to file information returns with the IRS and provide statements showing whether or not they offered their full-time employees health insurance coverage. ALEs can satisfy this requirement by completing Forms 1094 and 1095. The annual ACA reporting is required regardless of whether or not an ALE offered health insurance coverage.

Good-faith effort extended, but penalties may still apply

The extension of the good-faith effort relief applies to taxpayers who report incorrect or incomplete information if they can adequately demonstrate to the IRS that a good-faith effort was made to comply. However, the good-faith relief is not guaranteed, and many employers are facing large penalties for previous filing mistakes.

The IRS has stated that this relief does not apply to those who failed to provide or file a timely statement or return.

Individuals may file tax returns prior to receiving forms

Because of these extensions, individuals may not receive their Forms 1095-B or 1095-C by the time they are ready to file their 2018 individual income tax return. But taxpayers do not have to wait for the forms to file. While information on these forms may help with preparing a return, the forms are not required, and individuals can use other information about their health coverage to prepare their returns.

It should be noted that under the Tax Cuts and Jobs Act, the individual shared responsibility payment is reduced to $0 for individuals who fail to obtain health insurance effective January 1, 2019. However, the employer mandate and the ACA reporting requirements remain unchanged and employers are still required to comply.

How we can help

CLA's employee benefit plan professionals are well-versed in ACA reporting requirements. We can help you identify your full-time employees, prepare Forms 1094 and 1095 (B and C series), identify information that may result in fines, and and assist you with responses to IRS ACA penalty notices.

Our ACA services and resources can help reduce your compliance and penalty risk.