Deadlines Approaching for 1095 Reporting

IRS Notice 2018-06 announces a 30-day extension of the deadline to furnish 2017 Forms 1095-C to employees, until March 2, 2018.

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:

• March 2, 2018: extended deadline for furnishing the written statement (Form 1095-C) to full-time employees.
• February 28, 2018: deadline for filing Form 1094-C transmittal (and copies of related Forms 1095-C) with the IRS, if filing on paper.
• April 2, 2018: 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 2017 calendar year (in 2018, the normal deadline of March 31 falls on a Saturday, so the deadline moves to the next business day).

The IRS encourages employers to furnish 2017 statements as soon as they are able.  The 30-day extension for 2017 Forms 1095-C is automatic, so ALEs do not have to request extensions, and the IRS will not respond to extension requests.  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).

The IRS also extended good-faith transition relief to 2017 information reporting, which applies only to incorrect or incomplete information reported on Form 1095-C and not to a failure to timely furnish or file the Forms.

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