IRS extends 1094-C, 1095-C filing deadlines
As employers anxiously prepared for the upcoming deadlines for the 1094-C and 1095-C filings, the IRS dropped another holiday week surprise. They extended the due dates for the filing of these 2015 forms (Notice 2016-4). This extension of time was also granted to health insurers who will be providing coverage information to individuals who are covered by fully insured plans.
Applicable large employers will have almost two additional months to issue Forms 1095-C to individuals. 1095-Cs must now be distributed by March 31, 2016 (the original due date was February 1). The deadline for filing the forms with the IRS, including the 1094-C, has been extended by three months. The new IRS deadline is now May 31, 2016 (via mail) and June 30, 2016 (electronically).
The original deadline for providing individuals the 1095-C matched the deadline for furnishing the Form W-2 to employees and was intended to provide taxpayers information needed to file their federal tax returns. The IRS has acknowledged that this extension could cause problems for some individuals who will not have received their forms prior to submitting their tax returns. It has also commented that such individuals may rely on other information received from coverage providers and will not need to file an amended return or any corrections upon receipt of the forms. Individuals should keep the Form 1095-B or Form 1095-C with their tax records.
The government also indicated that they will accept filings for the original deadline dates for those employers who are ready. Employers should check with the vendors they are working with on these filings to see if timelines have shifted due to this extension.
About the Author
Christopher Nadeau is an Area President at Gallagher WGA. Mr. Nadeau counsels his department to develop and redesign employee benefits programs to match the corporate philosophy, long-term needs, and objectives of their clients. He is also an industry leader on Healthcare reform and the cost impact and administrative burden on employers.