IRS Extends Deadline for Providing ACA Forms to Individuals

December 6, 2018

The IRS has provided an extension of the deadline for large employers, as well as all employers that sponsor self-funded health plans, to provide health plan coverage information to full-time employees and their dependents under the Patient Protection and Affordable Care Act (ACA). Applicable large employers must report offers of ACA coverage they extend to full-time employees and their dependents, while employers that sponsor self-funded health plans must report the months of coverage for individuals who are actually enrolled in coverage. This information is transmitted to the affected individuals and the IRS on Forms 1094-B, 1095-B, 1094-C, and 1095-C. Forms 1095-B (for employers that sponsor self-funded plans and do not qualify as applicable large employers) and 1095-C (for applicable large employers) are supposed to be provided annually to individuals by January 31 for the prior calendar year.
In Notice 2018-94, the IRS has extended the due date for furnishing Forms 1095-B and 1095-C to individuals for 2018 from January 31, 2019 to March 4, 2019. The IRS said it will not automatically grant additional 30-day extensions to employers. IRS Notice 2018-94, however, does not extend the due date for filing the applicable forms with the Service. The deadline for paper filings with the IRS remains February 28, 2019. For forms filed electronically, the deadline remains April 1, 2019. The Service will still allow employers that timely file Form 8809 to receive an automatic 30-day extension of these filing deadlines.

The IRS Notice also continues the good faith transition relief that the Service has provided each year. The IRS typically will not assess filing penalties for incorrect or incomplete information where an employer made a good faith effort to comply with the reporting requirement. To qualify for transition relief, the employer must timely furnish the appropriate forms to individuals, as well as timely file the appropriate forms with the IRS.