- On Nov. 29, 2018, the IRS issued a notice extending the deadlines for certain entities to furnish forms 1095-C or 1095-B to employees and covered individuals about the health insurance coverage offered to them.
- The notice also extends good-faith transition relief for the 2018 filing year from penalties for incorrect and incomplete reporting on Forms 1094-B, 1095-B, 1094-C, and 1095-C.
On Nov. 29, 2018, the Internal Revenue Service (IRS) issued a notice extending the deadlines for certain entities to furnish forms 1095-C or 1095-B 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 on forms 1094-B, 1095-B, 1094-C, and 1095-C for the 2018 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 lookback.
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 2018 Form 1095-C has been extended from Jan. 31, 2019 to March 4, 2019.
- There is no change regarding the filing deadlines for paper filers (Feb. 28, 2019) and electronic filers (April 1, 2019).
- The provision regarding automatic extensions for filing information returns remains available via Form 8809.
- Good-faith transition relief from penalties under sections 6721 and 6722 for incorrect or incomplete information reporting on the returns is extended to the 2018 tax filing year. This relief also applied to the 2015 to 2017 tax filing years.
- There is no relief for failure to file or furnish in a timely manner.
The IRS does not anticipate extending the furnishing deadline or good-faith transition relief to 2019. 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.