On December 28, 2015, the Internal Revenue Service (the “Service”) issued Notice 2016-4 extending the deadline for information reporting requirements under the Patient Protection and Affordable Care Act (the “ACA”). The reporting requirements are intended to assist the Service in application of ACA penalties and were two-fold: an initial disclosure to the employee and a final report to the Service. These requirements were to be satisfied by the filing of Form 1095 (with different filings under Form 1095-B or 1095-C dependent on the type of insurance arrangement sponsored by the employer). The deadline for furnishing the form to the employee had been set for February 1, 2016. The deadline for filing Form 1095 with the Service was to be February 29 for non-electronic filers and March 31 for all employers who are “electronic filers” (filing greater than 250 single 1095 forms).
Notice 2016-4 has now extended those deadlines as follows:
New deadline for furnishing Form 1095 to employees: March 31, 2016.
New deadline for filing Form 1095 with the Service:
Non-electronic filers: May 31, 2016.
Electronic filers: June 30, 2016.