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January 10, 2018

The Internal Revenue Service (IRS) recently issued a notice extending certain due dates for 2017 ACA information reporting under Sections 6055 and 6056 of the Internal Revenue Code. Notably, the notice did not include new due dates for employers and other health coverage providers filing Forms 1094-B and 1095-B and/or 1094-C and 1095-C with the IRS. A copy of the notice can be viewed here.

Following the notice, employers and other health coverage providers must comply with the following due dates:

  • For providing Form 1095-B and Form 1095-C to employees and/or insureds, the due date is extended from January 31, 2018 to March 2, 2018.
  • For filing Forms 1094-B and 1095-B and/or 1094-C and 1095-C with the IRS, the due date remains February 28, 2018 (if not filed electronically) or April 2, 2018 (if filed electronically). The regulations, however, allow for an automatic 30-day extension to file such forms with the IRS following submission of a Form 8809, and an additional 30-day extension may be granted under certain hardship conditions (these extensions are not available for the 1095-B and 1095-C Forms furnished to employees/insureds).

The notice also provides short-term relief from penalties for failing to timely file an information return or for filing an incorrect or incomplete information return, if a filer can show that it made good-faith efforts to comply with the information reporting requirements. This relief is only available if the forms were filed on time.