A recent Newsline article discussed the upcoming deadlines for the Affordable Care Act’s (ACA) 2015 information reporting requirements under Internal Revenue Code (IRC) sections 6055 and 6056. On Dec. 28, 2015, the Internal Revenue Service (IRS) issued Notice 2016-4, which extends the deadlines for the 2015 information reporting requirements, both furnishing to individuals and filing with the IRS.

ACA includes new onerous information reporting requirements under IRC sections 6055 and 6056 that apply to employers with 50 or more full-time employees and full-time-equivalent employees, as well as employers of any size that self-insure. Effective in 2016, employers are required to report to the IRS health coverage offered (or not offered) in 2015 and provide a related statement to each full-time employee or covered individual.   

Specifically, Notice 2016-4 extends the deadlines for:

1)   furnishing to individuals the 2015 Form 1095-B, Health Coverage, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from Feb. 1, 2016, to March 31, 2016; and

2)   filing with the IRS the 2015 Form 1094-B, Transmittal of Health Coverage Information Returns; the 2015 Form 1095-B, Health Coverage; the 2015 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns; and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from Feb. 29, 2016, to May 31, 2016, if not filing electronically, and from March 31, 2016, to June 30, 2016, if filing electronically.

Additional Resources (note: the IRS has not updated the below guidance documents to include the new due dates):

Applicable large employers (those with 50 or more full-time employees and full-time-equivalent employees) can learn more about section 6056, read a Q&A and access the following forms on the IRS website. 

Applicable large employers that file 250 or more information returns must file the returns electronically through the ACA Information Returns (AIR) program.

Self-insured employers can learn more about section 6055, read a Q&A and access the following forms on the IRS website.

• 2015 Form 1095-B Health Coverage
• 2015 Form 1094-B Transmittal of Health Coverage Information Returns
• 2015 Instructions for Forms 1094-B and 1095-B

Self-insured employers that are applicable large employers are subject to the reporting requirements of both section 6055 and section 6056 and are required to use Form 1095-C and Transmittal Form 1094-C. Self-insured employers with fewer than 50 full-time or full-time equivalent employees should use Form 1095-B and Transmittal Form 1094-B.

To learn more about the ACA reporting requirements, register for the webinar on Jan. 27 at 2 p.m. (EST), titled, "Health Care Reform Update – Learn How the Affordable Care Act Will Impact your Company in 2016 and Beyond," which will be presented by ABC’s general counsel, Littler Mendelson.

*Employers are encouraged to consult counsel and/or their insurance brokers about complying with ACA.