Written by: Natalie Stevenson, Staff Accountant
The IRS has extended the due date for 2015 information reporting requirements (both furnishing to individuals and filing with the Internal Revenue Service) for insurers, self-insuring employers, and certain other providers of minimum essential coverage, and the information reporting requirements for applicable large employers.
Specifically, this notice extends the due date:
- (1) for furnishing to individuals the 2015 Form 1095-B, Health Coverage, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from February 1, 2016, to March 31, 2016, and
- (2) for filing with the IRS the 2015 Form 1094-B, Transmittal of Health Coverage Information Returns, the 2015 Form 1095-B, Health Coverage, the 2015 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from February 29, 2016, to May 31, 2016, if not filing electronically, and from March 31, 2016, to June 30, 2016 if filing electronically.
The IRS is prepared to accept filings of the information returns on Forms 1094-B, 1095-B, 1094-C, and 1095-C beginning in January 2016. Following consultation with stakeholders, however, the Department of the Treasury and the IRS have determined that some employers, insurers, and other providers of minimum essential coverage need additional time to adapt and implement systems and procedures to gather, analyze, and report this information. Notwithstanding the extensions provided in this notice, employers and other coverage providers are encouraged to furnish statements and file the information returns as soon as they are ready. Employers may be subject to penalties if they do not comply with these extended due dates.
Impact of Extensions for Applicable Large Employers
Applicable large employers now have until March 31, 2016 to furnish Form 1095-C to indi-viduals. In addition, they have until May 31, 2016 (June 30, 2016 if filing electronically) to file the 1095-C and the related transmittal form, 1094-C, to the IRS.
Impact of Extension for Self-Insured Employers
Self-insured employers – that is, employers who sponsor self-insured group health plans – now have until March 31, 2015 to furnish Form 1095-B to individuals. They also have until May 31, 2016 (June 30, 2016 if filing electronically) to file the 1094-B transmittal form to the IRS. (If self-insured employers are also considered an applicable large employer, they would fall under the reporting requirements for applicable large employers and use forms 1095-C and 1094-C.)
Impact of Extensions for Individual Taxpayers
Some individual taxpayers may be affected by the extension of the due date for employers to furnish information on Form 1095-C. If you work for an applicable large employer, generally those with 50 or more full-time employees, then you should be receiving a form. The Form 1095-C includes information on the coverage (if any) offered by the applicable large employer to the full-time employee. The information reported will assist the employee in determining eligibility for the premium tax credit, if applicable. The extension will not affect employees who enrolled in the employer-sponsored coverage or in other coverage that was not offered through the Marketplace; employees who for any other reason would not qualify for a premium tax credit (for example, an employee who qualifies for Medicare or has household income in excess of the limits); employees who enrolled in coverage through the Marketplace and received the benefit of advance payments of the premium tax credit based on a determination by the Marketplace that the employee's offer of employer-sponsored coverage was unaffordable; or employees who did not enroll in any coverage.
Some employees (and related individuals) who enrolled in coverage through the Marketplace but did not receive a determination from the Marketplace that the offer of employer-sponsored coverage was not affordable could be affected by the extension if they do not receive their Forms 1095-C before they file their income tax returns. As a result, for 2015 only, individuals who rely upon other information received from employers about their offers of coverage for purposes of determining eligibility for the premium tax credit when filing their income tax returns need not amend their returns once they receive their Forms 1095-C or any corrected Forms 1095-C. Individuals need not send this information to the IRS when filing their returns but should keep it with their tax records.
Similarly, some individual taxpayers may be affected by the extension of the due date for providers of minimum essential coverage to furnish information on either Form 1095-B or Form 1095-C. Individuals generally use this information to confirm that they had minimum essential coverage. Because, as a result of the extension, individuals may not have received this information before they file their income tax returns, for 2015 only individuals who rely upon other information received from their coverage providers about their coverage for purposes of filing their returns need not amend their returns once they receive the Form 1095-B or Form 1095-C or any corrections. Individuals need not send this information to the IRS when filing their returns but should keep it with their tax records.
If you'd like to learn more about health insurance coverage reporting feel free to contact our offices at (314)725-0324.