The Internal Revenue Service (IRS) has released Notice 2016-4, which extends the deadlines for the ACA's information reporting requirements under Sections 6055 and 6056 of the Internal Revenue Code. Sections 6055 and 6056 impose obligations on all Applicable Large Employers (generally those that averaged 50 or more full time equivalent employees during the previous year) to report information regarding the type of health care coverage they offer.
These provisions also impose reporting obligations on employers, regardless of size, that offer self-insured coverage. To comply with these requirements, employers must file informational returns with the IRS using either Form 1095-B or 1095-C for each individual on whom they are required to report, and also provide employees and certain non-employees with a copy of the relevant Form 1095-B or 1095-C. Additionally, employers must also submit an aggregate-level employer transmittal return using either Form 1094-B or 1094-C.
Notice 2016-4 extends the due date for furnishing the 2015 Form 1095-B and the 2015 Form 1095-C from February 1, 2016, to March 31, 2016. Notice 2016-4 also extends the due date for filing with the IRS the 2015 Form 1094-B and the 2015 Form 1094-C from February 29, 2016, to May 31, 2016, if not filing electronically, and from March 31, 2016, to June 30, 2016, if filing electronically.