A major requirement of the ACA has just been pushed back, and there’s little doubt employers are going to celebrate the delay.
What’s been delayed? The reporting requirements that tell the IRS which large employers (those with 50 or more full-time/full-time equivalent employees) offered employees the level of healthcare coverage required under Obamacare for the 2015 plan year.
They delays are welcome news for employers and plan sponsors. They’ve been scrambling to comply with the requirements and the nearing reporting deadlines after just getting the final rules and forms in late summer (here’s HR Morning’s plain-English breakdown).
But while the delays do give employers some much-needed breathing room, they don’t push the deadlines back that far, so employers need to maintain their sense of urgency.
The new deadlines
Here’s the lowdown on what’s due when:
- The due date for providing the Forms 1095-B and 1095-C to individuals has been pushed back from Feb. 1, 2016 to March 31, 2016.
- The date for submitting Forms 1094-B and 1094-C to the IRS — for those filing paper forms — has been pushed back from Feb. 29, 2016 to May 31, 2016.
- The date for submitting Forms 1094-B and 1094-C to the IRS electronically (e-filing is required for those submitting 250 or more forms) has been pushed back from March 31, 2016 to June 30, 2016.
Three more things you need to know
The IRS announced the delays in a new notice (Notice 2016-4); it’s reasoning for the delays being that it wanted to “make the system work as smoothly as possible.” Those are the words of Treasury Senior Advisor Mark Iwry.
Translation: As with other portions of the ACA, employers weren’t given the final rules/forms with enough time to fully prepare themselves to properly meet the original deadline.
But the delays themselves aren’t the only things employers must take note of. There are three other facets to the IRS’ announcement they must pay attention to:
- The deadline extensions only apply to the 2015 calendar year (2016 filing). For following years, all of the original deadlines will kick back in. Note: The due date for providing Forms 1095 to individuals was originally Jan. 31 but was moved to Feb. 1 of this year because Jan. 31, 2015 fell on a Sunday. Moving forward, the deadline is Jan. 31.
- There will be no extensions. The IRS has been offering some employers a 30-day reporting extension (and 60-day extensions in some limited situations). No such extensions are being offered now. Since the new deadlines are more generous than the previous extensions, any extensions offered are now void. The IRS expects all employers to be able to comply with the new deadlines, and no process will be put in place for requesting an extension from the new deadlines.
- The IRS won’t be lenient. The IRS expects all firms to apply “a good-faith” standard to complying with these new deadlines. Employers who fail to do so will face non-reporting penalties.