IRS Announces ESR Filing Deadline Extensions

Issued January 8, 2016

In our continuing efforts to keep you informed of developments with employer requirements in the Affordable Care Act (ACA), Paychex and its partners recently met with Internal Revenue Service (IRS) leadership to discuss the original deadlines to furnish and file returns set forth under the Affordable Care Act (ACA), notably for Forms 1094-C and 1095-C.

We’re pleased to inform you that on December 28, 2015, the IRS extended the deadline to furnish and file required forms for all required filers. The new deadlines are:

  • March 31, 2016, to deliver the 2015 Forms 1095-B and 1095-C to affected employees;
  • May 31, 2016, to manually file the 2015 Forms 1094-B, 1094-C, 1095-B, and 1095-C with the IRS—for employers who’re eligible for paper filing; and
  • June 30, 2016, to electronically file the 2015 Forms listed above with the IRS.

Per the IRS announcement, there will be no further extensions granted beyond these dates. Employers who fail to furnish or file by the extended deadlines may be subject to penalties from the IRS.

How Will This Affect Your Employees?

The new deadlines should not affect most employees. Individual taxpayers are not required to submit the 2015 Form 1095-C to the IRS with their personal income tax returns (Form 1040). Individual taxpayers who elect to file their income tax returns using other information provided by employers about their offers of health coverage—prior to receiving Form 1095-C—don’t need to amend their returns once they receive their Form 1095-C; however, they should retain the Form 1095-C when they receive it as proof of coverage