30-Day Extension for 1095 Reporting to Individuals

IRS Notice 2018-94 extends the due date for furnishing to individuals the 2018 Form 1095-B (Health Coverage) and Form 1095-C (Employer-Provided Health Insurance Offer and Coverage) from January 31, 2019 to March 4, 2019.

As background, under Section 6055 of the Affordable Care Act, employers with self-funded health plans must report information about minimum essential coverage to assist in enforcing the individual mandate penalty.  Under Section 6056, applicable large employers (ALEs), or employers with 50 or more full-time employees and full-time employee equivalents in the prior year, must report shared-responsibility information to assist in enforcing the play-or-pay penalty and determining eligibility for a premium credit.  Here are the three important deadlines for filing 2018 information:

• March 4, 2019: 30-day extended deadline for furnishing the written statement (Form 1095-C) to full-time employees.
• February 28, 2019: deadline for filing Form 1094-C transmittal (and copies of related Forms 1095-C) with the IRS, if filing on paper.
• April 1, 2019: deadline for filing Form 1094-C transmittal (and copies of related Forms 1095-C) with the IRS, if filing electronically.  Electronic filing is mandatory if the ALE is required to file 250 or more Forms 1095-C for the 2018 calendar year (in 2019, the normal deadline of March 31 falls on a Sunday, so the deadline moves to the next business day).

The IRS encourages employers to furnish 2018 statements as soon as they are able.  Employers may wish to notify affected employees of any delay in furnishing Forms 1095-C.  Employees do not need to wait to receive Form 1095-C before filing their returns, but they must indicate on their returns whether they had coverage or an exemption or if they will make a shared-responsibility payment (line 61).

If you have questions regarding this reporting requirement, call ASR Health Benefits at (616) 957-1751 or (800) 968-2449.