In a Benefits Alert dated November 25, 2015, we reminded you of the deadlines for meeting the Affordable Care Act's ("ACA") information reporting requirements under Sections 6055 and 6056 of the Internal Revenue Code. On December 28, 2015, the IRS issued Notice 2016-4 which extends those deadlines.

Code Section 6056 requires large employers to file and provide annual information returns and employee statements regarding the health coverage the employer offers (or does not offer) to its full-time employees. Code Section 6055 requires health insurers, employers with self-insured coverage, and other providers of minimum essential coverage to file and provide information returns and statements regarding the coverage.

New Deadline for Section 6055 Reporting

The IRS extended the due dates for filing IRS Forms 1094-B and 1095-B (for 2015 only) from:

  • February 28, 2016, to May 31, 2016, if not filed electronically.
  • March 31, 2016, to June 30, 2016, if filed electronically

The due date for providing individuals with Form 1095-B is also extended (for 2015 only) from January 31, 2016, to March 31, 2016.

New Deadline for Section 6056 Reporting

The IRS extended the due dates for filing IRS Forms 1094-C and 1095-C (for 2015 only) from:

  • February 29, 2016, to May 31, 2016, if not filed electronically.
  • March 31, 2016, to June 30, 2016, if filed electronically.

The due date for providing individuals with Form 1095-C is also extended (for 2015 only) from January 31, 2016, to March 31, 2016.

These new deadlines are designed to give employers additional time to collect the information required to be reported on the first forms, and to develop, test, refine and implement the systems and procedures employers may use for reporting for 2015 and later years. 

Finally, employers may still report earlier, if they wish, as the IRS advised that it will be ready to begin accepting Forms 1094-B, 1095-B, 1094-C and 1095-C in January 2016.