Tax Form

IRS and Treasury have issued guidance giving employers a little more time to figure out how to fill in the health coverage forms that are provided to employees and the IRS.

Under Notice 2016-4, released Dec. 28, employers have two additional months to provide health coverage forms to individuals and three additional months to provide the information to the IRS.

The amended 2016 due dates for the 2015 information reporting requirements are:


  • Forms 1095-B and 1095-C.  The deadline to submit these forms to employees is extended from by Feb. 1, 2016, to March 31, 2016.
  • Forms 1094-B and 1094-C with copies of 1095-B and 1095-C.  The deadline to submit these forms to the IRS by paper has been extended from Feb. 29, 2016, to May 31, 2016.
  • Forms 1094-B and 1094-C with copies of1095-B and 1095-C.  The deadline for employers to submit these forms to the IRS electronically, required for those submitting over 250 forms, has been extended from March 31, 2016, to June 30, 2016.  

The relief is likely a response to requests for more time from employers unprepared for the first year of mandatory information reporting.  Initially slated to go into effect last year, transition relief made 2014 reporting voluntary. 

In a concurrent press release, Treasury said that most taxpayers will not be affected by the extension. “Like last tax filing season, most individuals will simply check a box on their tax return indicating they had health coverage for the entire year.” 

Employers, however, should take special note of requirements and deadlines applicable to them. Those who fail to file or furnish, or who file or furnish incorrect information returns, face an increased penalty of $250 per form thanks to the Trade Preferences Extension Act of 2015 (Pub. L. No. 114–27).  The fine, up from $100 per form, includes Forms 1095-B and 1094-B.

See related article, IRS Extends Some Employer ACA Reporting Deadlines.

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