ACA Reporting Deadlines Extended

On December 28th the IRS issued Notice 2016-4 which extended the deadlines for providing the 2015 Forms 1094-B, 1094-C, 1095-B, and 1095-C as follows:

  • Distribute to employees: March 31, 2016 (was February 1)
  • File with IRS via paper: May 31, 2016 (was February 29)
  • File with IRS electronically: June 30, 2016 (was March 31)

Due to the delayed deadlines, individuals may not receive forms 1095-B and/or 1095-C in time to complete their individual tax return prior to April 15th; therefore, the IRS has indicated that taxpayers do not need to wait until they receive these forms to file their taxes. Taxpayers will comply with filing requirements if they simply check a box on their 1040 that indicates they had coverage for the calendar year. Additionally, individuals will not need to file an amended tax return once their Forms 1095-B and/or 1095-C are received, but they should maintain a copy for their files.

It is important to note that taxpayers who had marketplace coverage during the year and received advance premium tax credits will need to wait until they receive their Form 1095-A before filing their 2015 tax return; therefore, Form 1095-A remains due by February 1, 2016.

The IRS has issued a series of questions and answers about Forms 1095-A, 1095-B, and 1095-C. Individuals may find these Q&As helpful as they provide an overview of the forms, identify who will provide them, and describe the purpose of the forms.