The Internal Revenue Service (IRS) has extended the due dates for certain 2018 information reporting requirements imposed by the Affordable Care Act (ACA) under section 6055 and 6056 of the Internal Revenue Code. Specifically, Notice 2018-94 extends the due date to distribute Forms 1095-B (Health Coverage) and 1095-C (Employer-Provided Health Insurance Offer and Coverage) to employees from January 31, 2019 to March 4, 2019. The extension is automatic, so employers and providers do not have to request it.
The Department of the Treasury and the IRS determined that employers and insurers could use the additional time to gather and analyze the information to prepare the forms. If this feels like déjà vu, it’s because they provided the same type of deadline extension last year.
However, a similar need for additional time for filing information returns to the IRS was not identified. Therefore, these due dates remain for filing to the IRS:
- February 28, 2019 – Form 1094-B or Form 1094-C to the IRS if filing on paper, along with Form 1095-B or Form1095-C.
April 1, 2019 – Form 1094-B or Form 1094-C to the IRS if filing electronically, along with Form 1095-B or Form 1095-C.
Required Reporting Background: Under the Affordable Care Act (ACA), applicable large employers (ALEs)—those with at least 50 full-time employees, including full-time equivalent employees, on average during the prior year—are required to report information related to the health coverage they offered (or did not offer) their employees working 30 or more hours per week. Employers offering self-insured health plans are also required to report information related to their health plan offerings.
Tax Filing Information: Due to the extension, individuals may not receive their Forms 1095-B or 1095-C by the time they file their tax returns. Employees are still able to file their tax returns using other information about their health coverage if they do not have the Forms 1095-B or 1095-C in time. MRA has a sample letter that can be modified and used for the purpose of communicating the deadline extension to employees.
Going forward. The Notice noted that because the individual shared responsibility payment is reduced to zero for months beginning after December 31, 2018, the IRS is studying whether and how the reporting requirements under section 6055 should change, if at all, for future years.
ACA Reporting Forms and Instructions:
- Instructions for Forms 1094-C and 1095-C
Form 1094-C Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
Form 1095-C Employer-Provided Health Insurance Offer and Coverage
Instructions for Forms 1094-B and 1095-B
Form 1094-B Transmittal of Health Coverage Information Returns
Form 1095-B Health Coverage 2018
Source: IRS.gov; Lynell Meeth, Director of Member Content, MRA – The Management Association; CCH/Wolters Kluwer