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IRS Extends Deadlines for Issuing Forms 1095-B and 1095-C

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On December 22, 2017, the IRS announced an extension for the due dates for furnishing Forms 1095-B, Health Coverage, and 1095-C, Employer-Provided Health Insurance Offer and Coverage, to individuals.

As outlined in IRS Notice 2018-6, the forms are now required to be furnished to individuals by March 2, 2018, instead of the original deadline of January 31, 2018. No additional extension will be permitted beyond March 2, 2018. However, the due date for filing these forms with the IRS remains February 28, 2018, or April 2, 2018, if filing electronically. The availability of an extension of time to file these forms with the IRS using Form 8809 is unaltered.

The IRS has also extended relief for reporting entities that can show that they have made good-faith efforts to comply with the information-reporting requirements of Forms 1095-B and 1095-C for 2017 (both for furnishing to individuals and for filing with the IRS) for incorrect or incomplete information reported on the return or statement.

This relief applies to missing and inaccurate taxpayer identification numbers and dates of birth, as well as other information required on the return or statement. It does not apply to reporting entities that do not make a good-faith effort to comply with the regulations or that fail to file an information return or furnish a statement by the due dates (as extended under the rules described above).

IRS Form 1095-B

IRS Form 1095-B is used to report certain information to the IRS and to taxpayers about individuals who are covered by minimum essential coverage and therefore aren’t liable for the individual shared responsibility payment.1 Form 1095-B should be filed by:

  • Health insurance issuers and carriers for most health insurance coverage, including individual market coverage and insured coverage sponsored by employers; and
  • Small employers sponsoring self-insured group health plans that aren’t subject to the employer shared responsibility provisions.2

Employers that offer employer-sponsored self-insured health coverage to non-employees who enroll in the coverage may use Form 1095-B to report coverage for those individuals and other family members.3

IRS Form 1095-C

IRS Form 1095-C is required to be filed by an applicable large employer (ALE) for each employee who was a full-time employee of the ALE for any month of the calendar year.4

Please contact us with any questions.

 


1The recently enacted tax reform legislation effectively repealed the individual shared responsibility payment provision of the Affordable Care Act, but not until January 1, 2019.

2Instructions to Form 1095-B, page 1, under the heading “Who Must File.”

3Note that in general, employers sponsoring self-insured health plans report information regarding minimum essential coverage using Part III of Form 1095-C in lieu of Form 1095-B.

4Instructions to Form 1095-C, page 1. An ALE is any employer with 50 or more full-time employees (including full-time equivalent employees) during the tax year.

Ted Batson

Ted serves as partner, tax counsel, and Professional Practice Leader – Tax. As a certified public accountant and tax counsel, Ted advises exempt organizations of all sizes on a wide range of issues. This includes consulting on tax and employee benefit related matters, representation before state and federal tax authorities, and assistance with firm audit or advisory engagements to formulate advice and counsel on important operating and tax issues. Ted also leads the firm’s tax preparation practice, including IRS Forms 990 and 990-T and related state forms.

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