For 2015, employers had extra time to complete their Section 6056 and Section 6055 reporting thanks to transition relief from the IRS. Of course, even with that extra time, there were still many challenges faced by employers and vendors regarding producing the forms and communicating the impact to employees.
Regarding the need to next report on 2016′s activity, there has not yet been an indication that the IRS will provide any relief from the normal deadlines. (Update: On 11/18/2016, the IRS announced a deadline extension for Form 1095-C distribution to employees.)
This means that employers will need to act quickly in order to distribute the required forms to employees in January 2017 and then file returns with the IRS on time.
The 2016 reporting deadlines for specific forms are as follows:
- January 31, 2017 (Note: On 11/18/2016, the IRS extended the deadline to March 2, 2017): Forms 1095-B and 1095-C due to employees (to be postmarked, if mailed, or sent by email if applicable conditions are met)
- February 28, 2017: Forms 1094-B, 1095-B, 1094-C and 1095-C due to the IRS if filing on paper
- March 31, 2017: Forms 1094-B, 1095-B, 1094-C and 1095-C due to the IRS if filing electronically
Any employer filing 250 or more forms must file their returns electronically, unless the employer obtains a waiver.
Employers that need extra time to file returns with the IRS can request an extension by completing IRS Form 8809 before the filing deadline. Additional extensions may be available if certain hardship conditions apply. Employers can also request an extension of time to furnish employee statements by sending a letter to the IRS. More information about extensions is available in the instructions for each form.
Support from CBG Benefits
While many of our clients will once again work directly with their payroll or HRIS software vendor to produce these forms, our team is available to provide ACA reporting support in a number of ways. This includes utilizing our standalone solution to produce Form 1095-C and Form 1094-C documents, reviewing forms that have been generated by a third-party for accuracy, and providing employee-facing communication materials to explain what the forms mean.
If you’d like to learn how we can help your organization in any of those areas, please contact our team at 781-759-1222.