Applicable large employers (ALE), or employers with more than 50 full-time equivalent employees in the prior year, must file Forms 1095-C and 1094-C on an annual basis. On November 22, 2021, the Internal Revenue Service (IRS) issued proposed regulations that will permanently and automatically extend the deadline by 30 days for employers to provide Form 1095-C to employees.
The initial filing deadline to provide 2021 forms to employees was set at January 31, 2022. The extension would permanently move that deadline to March 2, 2022. Since 2015, when the reporting rules went into effect, the IRS has provided a 30-day extension of filing the employee copies each year. These regulations will finally make those extensions permanent.
The IRS did not extend the due date for filing Form 1094-C. It, therefore, remains at February 28, 2022, if filing on paper, or March 31, 2022, if filing electronically.
Fully insured plans
In fully insured plans, insurers are also required to provide employees with Form 1095-B. The IRS has indicated that it will not assess a penalty for the failure to provide Form 1095-B if a notice is posted on the insurer’s website stating that individuals may request a copy of Form 1095-B. Form 1095-B must be provided within 30 days of the request for the form.
For a copy of regulations, please click here.
We will continue to monitor ACA-related requirements and provide employers with updates as available. If you have any questions, please consult your Sikich tax advisor.