IRS Grants Extension for ACA Reporting Deadline in 2020

As in years past, the Internal Revenue Service (IRS) has announced that it will extend the deadline for employers to provide employees with Form 1095-C or 1095-B. Recognizing that some employers, insurers and other coverage providers need additional time to gather and analyze the information, Notice 2019-63 now provides an additional 31 days for furnishing the 2019 Form 1095-B and Form 1095-C, extending the due date from January 31, 2020, to March 2, 2020. The due date for filing returns with the IRS for 2019 is not affected; please see table below.

This extended furnishing deadline applies automatically to all reporting entities, and the IRS will not grant any additional extensions of time to furnish Forms 1095-B and 1095-C. As a result, the IRS will not formally respond to any extension requests that have already been submitted.  Employers and other coverage providers are still encouraged to furnish 2019 statements to individuals as soon as they are able.  The Notice further provides a one-year extension on good-faith reporting relief and some distribution relief for small employers.

The IRS has released drafts of Forms 1095-B, Health Coverage, 1094-B, Transmittal of Health Coverage Information Returns, 1095-C, Employer-Provided Health Insurance Offer and Coverage, and 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns.  These draft versions propose minimal changes, primarily reflecting new dates, and the elimination of the Individual Mandate penalty. Final forms are expected to be issued before the start of the New Year, making now the perfect time to review enrollment and employment records for accuracy.

As we reported earlier this fall, for plan years beginning in 2020, employer-sponsored coverage will be considered affordable if the employee’s required contribution for self-only coverage does not exceed 9.78% of the employee’s household income for the year.

This overview is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.

If you have any further questions, contact the Employee Benefits Management Group (EBMG) at Rose & Kiernan, Inc. here or by calling (800) 242-4433.