On December 28, the IRS issued Notice 2016-4, which extends certain deadlines for Affordable Care Act reporting. Specifically, the IRS has extended the deadlines for forms 1094-C and 1095-C (as well as forms 1094-B and 1095-B for providers of health coverage).

In part, Notice 2016-4 provides that Applicable Large Employers (“ALE”), generally employers with 50 or more full-time employees, now have until March 31, 2016, to furnish to employees Form 1095-C, Employer-Provided Health Insurance Offer and Coverage. Coverage providers, including self-insured employers, have until March 31, 2016, to provide Form 1095-B to individuals. The previous deadline was February 1, 2016.

ALEs also now have until May 31, 2016, to then file with the IRS copies of the 1095-C forms, along with the 1094-C transmittal form. The previous deadline was February 29, 2016. If filing electronically, the new deadline is June 30, 2016 (previously March 31, 2016). Coverage providers have the same extension to file 1094-B.

Summary of New Deadlines

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