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IRS Extends Deadlines for Health Plan Information Reporting Under the ACA

The Internal Revenue Service (IRS) recently provided good news to employers struggling to comply with the new Affordable Care Act (ACA) reporting requirements in the form of Notice 2016-4 (the Notice). The Notice extends the due dates for 2015 information reporting under Sections 6055 and 6056 of the Internal Revenue Code. This extension effectively provides insurers, self-insured employers, and other applicable large employers an additional two months to furnish forms to employees and an additional three months to complete their filings for 2015.

Under the ACA, health insurance issuers, self-insuring employers, and other providers of minimum essential coverage are required to file and furnish annual information returns and statements regarding coverage provided. The ACA also requires applicable large employers – generally those with 50 or more full-time employees/full-time equivalent employees in the previous calendar year – to file and furnish information returns and statements regarding the health insurance it offers, or does not offer, to those full time employees.

The Notice extends the deadline for employers to furnish Forms 1095-B and 1095-C to employees regarding the employees’ health plan coverage from February 1, 2016, to March 31, 2016. The deadline for employers to file the required information returns with the IRS has also been extended to May 31, 2016, for paper filings and June 30, 2016, for electronic filings.

These extensions are applicable only to the 2015 forms that will be filed early in the 2016 calendar year and replace any extensions which may have been requested by employers. Importantly, employers who fail to meet the filing deadlines could be subject to penalties, however the Notice provides that penalties for late returns may be abated for reasonable cause, such as difficulties beyond the employer’s control in gathering and transmitting required data. The IRS urges employers and other reporting entities to adhere to the extended deadlines and to timely furnish statements to employees and file information returns instead of waiting for the deadline.

Employers and other reporting entities should use the additional time granted by this extension to ensure they provide complete and accurate data to employees and the IRS as required by the ACA.

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About this Author

Anne B. Compton-Brown, Barnes Thornburg Law Firm, Atlanta and Chicago, Health Care Law Attorney
Associate

Anne B. Compton-Brown is an associate in the Atlanta and Chicago offices of Barnes & Thornburg LLP and a member of the firm’s Healthcare Department and Data Security and Privacy Practice Group. Ms. Compton-Brown focuses her practice on transactional and regulatory matters for a variety of providers in the healthcare industry.

Ms. Compton-Brown routinely counsels clients on scope of practice issues for licensed providers; contract drafting and negotiation; HIPAA compliance; physician and ancillary provider employment matters; physician-...

312-214-5636
Michael G. Paton, Barnes Thornburg Law Firm, Indianapolis, Corporate and Employment Law Attorney
Partner

Michael G. Paton is a partner with Barnes & Thornburg LLP, resident in the firm’s largest office in Indianapolis, Indiana where he is a member of the Corporate Department and Chairman of the Compensation and Employee Benefits Practice Group. For over 25 years he has concentrated his practice on the many legal issues surrounding employee benefits. His “full service” practice encompasses a broad spectrum of activities, including drafting and design of both qualified and non-qualified retirement plans, cash balance and other "hybrid" plans, 401(k) plans and employee stock ownership plans (ESOPs). He counsels regional and national clients extensively on legal issues involved in the design and administration of health, “cafeteria,” and other fringe benefit plans, including the HIPAA privacy and security requirements, and most recently on the interpretation of provisions of the Patient Protection and Affordable Care Act (PPACA). His practice also includes counseling clients with respect to executive compensation issues, including compliance with the requirements of Section 409A. As part of his administrative practice he is closely involved with governmental agencies, including the Department of Labor and the Internal Revenue Service.

Mr. Paton also advises a number of tax-exempt and governmental employers on employee benefit matters relating to qualified plans, 403(b), 457(b) and 457(f) plans and 409A compliance.

Mr. Paton has been a frequent participant in employee benefit seminars on a variety of topics including PPACA, qualified retirement plans, ESOPs, health benefit plans, fiduciary responsibilities and other employee benefits issues. 

317-231-7201
Mark E. Rust, Barnes Thornburg Law firm, Chicago, Corporate, Finance and Healthcare Law Attorney
Partner

Mark Rust is Managing Partner of the Chicago office of Barnes & Thornburg, LLP, and Chair of the firm’s national Healthcare Department. Mr. Rust concentrates his practice in transactional, regulatory and medical-legal issues affecting healthcare entities and provider organizations. For nearly 30 years he has written about or practiced in healthcare law, writing in a wide variety of publications from theJournal of the American Bar Association to USA Today. He is listed as a notable healthcare lawyer in Chambers USA, Top Healthcare Lawyers of Illinois,Superlawyers...

312-214-8309