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IRS Extends ACA Deadline for Employers to Furnish Forms to Employees and on Good-Faith Transition Relief for 2019

The IRS has extended deadlines for employers to furnish forms as part of their Affordable Care Act requirements. Here are some key details and important dates to know.
ACA deadlines
  • On Dec. 2, 2019, the IRS issued a notice extending the deadlines for certain entities to furnish forms 1095-C to employees and covered individuals about the health insurance coverage offered to them.
  • The notice also extends good-faith transition relief for the 2019 filing year from penalties for incorrect and incomplete reporting requirements.

The Internal Revenue Service (IRS) issued a notice on Dec. 2, 2019, that extended the deadlines for certain entities to furnish forms 1095-C to employees and covered individuals about the health insurance coverage offered to them. The notice also prolongs good-faith transition relief from penalties for incorrect and incomplete reporting requirements for the 2019 filing year.

In general, applicable large employers (ALEs) are employers that had an average of at least 50 full-time employees, including full-time-equivalents, in the preceding calendar year. Bear in mind that new employers determine their status using their anticipated employee count and look at their current year data as opposed to their look-back data.

ALEs must report the health insurance coverage information they offered on a Form 1095-C for each full-time employee. These forms are all filed with a transmittal Form 1094-C. Additionally, ALEs that sponsor self-insured health plans report health coverage information for each individual enrolled on a Form 1095-C. This includes the employee, employee’s family members, and non-employees. They have the option to report health coverage information for non-employees such as retired employees on a Form 1095-B, which are filed with the transmittal Form 1094-B. Non-ALEs that sponsor self-insured health plans report coverage information on 1095-B, not 1095-C.

Here are the key points for employers:

  • The due date for furnishing 2019 Form 1095-C is extended from Jan. 31, 2020, to March 2, 2020.
  • Good-faith transition relief from penalties under sections 6721 and 6722 for incorrect or incomplete information reporting on the returns is extended to the 2019 tax filing year. 
  • The provision regarding automatic extensions for filing information returns remains available via Form 8809.
  • There are no extensions to employer filing deadlines. Feb. 28 and March 31, 2020, for Forms 1094-C and 1095-C for paper and electronic filers, respectively, remain unchanged.
  • There is no relief for employers for failure to file or furnish in a timely manner.

Keep in mind, employers that do not provide accurate or complete information may be required to respond to IRS notices and correct any errors. Ultimately, it is easier to complete and file returns correctly the first time as researching, correcting and responding to the IRS later can be a much more complex and time-consuming process.

Businesses that need help managing due dates and compliance with other employer shared responsibility provisions of the Affordable Care Act can turn to Paychex.

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Laurie Savage is Senior Compliance professional, leading robust legislative research efforts analyzing intricate policy, including the Affordable Care Act (ACA), paid leave, tax reform and recently, legislation responding to the COVID-19 pandemic.
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* This content is for educational purposes only, is not intended to provide specific legal advice, and should not be used as a substitute for the legal advice of a qualified attorney or other professional. The information may not reflect the most current legal developments, may be changed without notice and is not guaranteed to be complete, correct, or up-to-date.

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