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Deadlines Extended for Affordable Care Act’s 2015 Information Reporting Requirements

The Internal Revenue Service (IRS) recently issued Notice 2016-4, which extends the deadlines for the 2015 information reporting requirements under the Affordable Care Act (ACA). 

ACA includes new information reporting requirements under IRC sections 6055 and 6056 that apply to employers with 50 or more full-time employees and full-time-equivalent employees, as well as employers of any size that self-insure. Effective in 2016, employers are required to report to the IRS health coverage offered (or not offered) in 2015 and provide a related statement to each full-time employee or covered individual.   

Specifically, Notice 2016-4 extends the deadlines for:

1)   Furnishing to individuals the 2015 Form 1095-B, Health Coverage, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from Feb. 1, 2016, to March 31, 2016; and,

2)   Filing with the IRS the 2015 Form 1094-B, Transmittal of Health Coverage Information Returns; the 2015 Form 1095-B, Health Coverage; the 2015 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns; and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from Feb. 29, 2016, to May 31, 2016, if not filing electronically, and from March 31, 2016, to June 30, 2016, if filing electronically.


To learn more about the ACA reporting requirements, the IRS has issued an ACA Health Care Guidance Document, Questions and Answers on Reporting of Offers of Health Insurance Coverage by Employers, which can be viewed at https://www.irs.gov/Affordable-Care-Act/Employers/Questions-and-Answers-on-Reporting-of-Offers-of-Health-Insurance-Coverage-by-Employers-Section-6056