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New IRS Guidance Extends ACA Information Reporting Due Dates

2016-01-12 11:00:00

In the past, I posted about this year marking the first year in history that employers are responsible for Annual Health Care Reporting – and the introduction of new IRS Forms, in particular the Form 1095-C, Employer-Provided Health Insurance Offer and Coverage.

On December 28, 2015 the Internal Revenue Service (IRS) extended the due dates for certain 2015 information reporting requirements under the Affordable Care Act (ACA), including the Form 1095-C. In Notice 2016-4, the IRS announced an automatic 2-month extension of the deadline for furnishing the applicable ACA forms to individuals and an automatic 3-month extension of the deadline for filing the applicable ACA forms with the IRS. The relief applies to applicable large employers required to furnish employees and file with the IRS information under the Internal Revenue Code section 6056 reporting requirements, as well as to health insurers, employers that sponsor self-insured health plans and other providers of minimum essential coverage required to furnish individuals and file with the IRS information under the Code section 6055 reporting requirements.

Specifically, the Notice extends the deadline for furnishing to individuals the 2015 Form 1095-C, and the deadline for filing Forms 1095-C and corresponding 2015 Form 1094-C, Transmittal of Employer Provided Health Insurance Offer and Coverage Information Returns, as follows:

Previous IRS Due Date New IRS Due Date
Forms 1095-C were due to individuals byFebruary 1, 2016 March 31, 2016
Forms 1094-C and 1095-C were required to be filed with the IRS if filing on paper byFebruary 29, 2016 May 31, 2016
Forms 1094-C and 1095-C were required to be filed with the IRS if filing electronically by March 31, 2016 June 30, 2016


The IRS likewise extended the due dates for the 2015 “B” Forms.

What does this mean to you?

Applicable large employers now have additional time to provide Form 1095-C to applicable individuals (generally, full-time employees as well as individuals receiving health coverage under a self-insured health plan) without being penalized by the IRS. These employers also have additional time to file Forms 1094-C and Form 1095-C with the IRS.   If you are an applicable large employer, you do not need to file or submit anything with the IRS to take advantage of these new due dates. If you previously submitted an extension request with the IRS, the new dates listed above also apply to you and the IRS will not respond to your previous extension requests nor grant any additional extensions for 2015 forms. For more information on the IRS announcement, see IRS Notice 2016-4 (issued on December 28, 2016) and the related Eye on Washington, New IRS Guidance Extends ACA Information Reporting Due Dates.

Also, join us for our ACA Special Edition Webcast: Understanding the Impact of the IRS ACA Annual Reporting Extension on January 12th.

Pete Isberg 160

Pete Isberg, Vice President, Government Relations at ADP

Pete Isberg is responsible for managing legislative and regulatory affairs covering a wide variety of employer compliance matters, including employment tax payments and reporting, and major legislative trends and initiatives such as the Affordable Care Act.  He has over 30 years of experience in working with state legislatures and Congress, as well as the IRS and state revenue, workforce development, child support enforcement and municipal tax authorities concerning employment tax administration, withholding and information and reporting issues.  He holds an MBA in Finance from California State Polytechnic University.


Ellen FeeneyEllen Feeney VP, Counsel Health Care Reform ADP

Ellen Feeney is Vice President, Counsel at ADP specializing in Health Care Reform. Ms. Feeney is part of the leadership team for ADP Health Compliance and provides compliance support related to the Affordable Care Act across ADP. She has extensive experience providing business training and day-to-day advice on payroll, HR and Health Care Reform compliance. Ms. Feeney earned her law and undergraduate degrees from the University of Notre Dame.



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