You Have More Time! The ACA Reporting Deadline Is Extended

The Affordable Care Act (ACA) 2019 reporting deadline was extended from January 31, 2019 to March 4, 2019 in IRS Notice 2018-94. The Notice extends the date that employers and insurers must provide individual statements on 2018 health coverage. Also extended is good faith transition relief for incorrect/incomplete reports due in 2019. This transition relief applies to the form’s information, and the deadline is not lengthened.

The impacted forms and sections are the following: 2018 Form 1095-B, Health Coverage, 2018 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, and section 6721 and 6722 penalties to the 2018 information reporting requirements under sections 6055 and 6056.

The IRS stated within the Notice that taxpayers do not have to wait to receive Forms 1095-B and 1095-C before filing their returns. Due to the extension, individuals may not receive the forms in time to file their 2018 tax returns. Taxpayers in this situation are to follow guidance provided by their coverage provider or employer. In addition, if employers requested a 30-day extension prior to this announcement, the IRS will not take notice of the request as it is now unnecessary.

However, individuals that choose to submit Form 8809 (the automatic 30-day extension form) before the due date can still do so. Please note that this Notice extends the date for filing with the IRS and does not extend the deadline to provide the forms to employees. Without an extension the deadline to file timely with the IRS for 2018 forms 1094-B, 1095-B, 1094-C, and 1095-C—is February 28, 2019 (if not filing electronically) and April 1, 2019 (if filing electronically).

It is encouraged to send forms as soon as possible despite the extension. For help with this or other ACA questions, please contact our employee benefits experts.

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