ACA Year-End Reporting – IRS Extends Individual Distribution

At the end of November the IRS released Notice 18-94 announcing a deadline extension for the distribution of Forms 1095-B and 1095-C to individuals from January 31, 2019, to March 4, 2019This extension is provided without the need to submit Form 8809.
This notice did NOT apply to the deadline for filing forms (1094-B, 1095-B, 1094-C, and 1095-C) with the IRS by February 28, 2019 (April 1, 2019 if filing electronically). To receive an automatic 30 day extension for this filing employers and vendors must submit Form 8809 before the filing deadline.
While this notice extends the January 31st deadline, the IRS continues to encourage employers and carriers to distribute and file forms as soon as they are able. Therefore, many payroll companies and carriers will likely continue to process these forms in early January.
We recommend employers take time NOW to review and correct 2018 employee and benefit data related to your ACA reporting. Many payroll companies only provide a week or so in the beginning of January to review ACA draft forms before final approval and filing is required.
If there are updates required for hours or benefits missing, now is the time to make these updates. Therefore, in early January all you will have to do is review final December 2018 data and approve the forms.
Other 2018 reporting reminders:
  • “Plan Start Month” – this box remains optional in Part II of Form 1095-C in 2018
  • Minor change to Form 1095-C – line 1 in part I and column (a) in part III provides dividers for the entry of the individual’s first name, middle initial, and last name. The new layout will presumably ensure all Forms 1095-C are completed with an identical name structure. By having a separate field for an employee’s last name, we are hopeful the IRS will be able to solve many of the TIN error issues.