As we explained in an earlier Client Alert, the Affordable Care Act (ACA) imposes two different reporting obligations on employers. The deadlines were to have been in the first quarter of 2016. Yesterday, however, the IRS announced that it has extended those deadlines.

Large Employer Reporting

A large employer must send an individual report (Form 1095-C) to each employee who was full-time for at least one month in 2015.

  • The deadline for providing this report has been extended until March 31, 2016.

The employer must also file the individual reports, together with a transmittal report (Form 1094-C), with the IRS. Employers who issue 250 or more individual reports must file electronically.

  • The deadline for paper filings has been extended until May 31, 2016.
  • The deadline for electronic filings has been extended until June 30, 2016.

A large employer must comply with these reporting obligations no matter whether it offered health coverage or not, and no matter whether the coverage was fully-insured or self-funded.

Minimum Essential Coverage Reporting

Any entity that provided minimum essential coverage to any individual in 2015 must send an individual report (Form 1095-B) to each person who was covered for at least one month in 2015.

  • The deadline for providing this report has been extended until March 31, 2016.

The entity must also file the individual reports, together with a transmittal report (Form 1094-B), with the IRS. Entities that issue 250 or more individual reports must file electronically.

  • The deadline for paper filings has been extended until May 31, 2016.
  • The deadline for electronic filings has been extended until June 30, 2016.

An employer that offered self-funded coverage must comply with these reporting obligations no matter whether it is "large" or "small." (However, exceptions may apply to employers whose self-funded coverage was through a multiemployer or multiple-employer welfare arrangement.)