On Dec. 28, 2015, the Internal Revenue Service (IRS) released Notice 2016-4, which extends filing and distribution deadlines for the employer reporting requirements required under the Affordable Care Act (ACA). This extension will give CFA members more time to ensure full compliance with the law.
ACA’s employer reporting requirements are mandated under Sections 6055 and 6056 of the Internal Revenue Code (IRC). Under IRC Section 6055, self-insured employers must file forms showing the months in which the individuals were covered by “minimum essential coverage.” Under IRC Section 6056, applicable large employers (those with 50 or more full-time equivalent employees) must file forms detailing employee offers and related coverage with the IRS (and distribute to employees). In most cases, employers will use Forms 1094-B and 1095-B and/or Forms 1094-C and 1095-C to comply with IRC Sections 6055 and 6056.
Under Notice 2016-4, the deadline for employers to distribute forms to employees and covered individuals has been extended from Feb. 1 to March 31, 2016. The deadline for employers to file with the IRS has been extended from Feb. 29 to May 31, 2016 (for paper filers) and from March 31 to June 30, 2016 for electronic filers.