May 27, 2020

May 26, 2020

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IRS Extends ACA Reporting Deadline Again This Year

For the third consecutive year, the IRS has extended by 30 days the deadline for health plan sponsors to furnish Forms 1095-B and 1095-C to individuals. A 30-day extension would place the deadline on a Saturday, so this year’s reprieve will allow employers, health insurers, and other plan sponsors to distribute the forms on or before March 4, 2019, rather than January 31.

The new guidance does not extend the deadlines for submitting the forms, along with Forms 1094-C and 1094-B, to the IRS. Those deadlines remain February 28, 2019, for paper forms and March 31, 2019, for electronic filings. Those submitting paper forms should take note that the IRS filing deadline precedes the date for providing the forms to individuals.

Also following prior years’ guidance, the IRS has extended good-faith relief to filers who submit incomplete or incorrect information in their 2018 Forms 1094 and 1095. To qualify for this relief, the reporting entity must show that it made good-faith efforts to comply with requirements. However, this relief does not cover a missed deadline for reporting.

Employers should be prepared to respond to inquiries about coverage from employees who are filing their tax returns for 2018 early and may wish to keep in mind that the legislative repeal of the individual mandate assessments under the ACA does not take effect until 2019.

The forms and instructions for reporting on the 2018 year include:

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About this Author

Edward I. Leeds, Philadelphia attorney, Ballard Spahr Law firm, Employee Benefits and Executive Compensationattorney

Edward I. Leeds concentrates on issues relating to the design, administration, and taxation of health and other welfare benefit plans. His practice has evolved with the laws and market forces that shape those plans. Mr. Leeds advises clients about compliance with the Affordable Care Act, HIPAA, HITECH, COBRA, cafeteria plan rules, and other legal requirements. He prepares clients for audits of their privacy and security measures under HIPAA and advises them about the rules governing wellness initiatives.

Mr. Leeds represents employers in the negotiation and drafting of contracts...