ACA Reporting Requirements Postponed

Written by Eva A. Rasmussen

The IRS recently issued IRS Notice 2016-4 which delays the deadlines for providing employees and the IRS information about employer-provided health coverage. The new deadlines are:

Form Recipient Original Deadline New Deadline
1095-B/C Employee February 1, 2016 March 31, 2016
(Not Electronically filed)
IRS February 29, 2016 May 31, 2016
(Electronically Filed)
IRS March 31, 2016 June 30, 2016

These new deadlines apply only for the 2015 filings and distributions that will be filed or distributed in 2016. The information on the forms are reported on a calendar year basis regardless of the applicable plan year. As a result of these uniform automatic extensions, the IRS will not issue individual automatic or permissive extensions. Individuals who file their 2015 tax returns before receiving a 2015 1095-B/C form may rely on other information provided by their employers to determine if they are eligible for a premium tax credit. Once they receive the 1095-B/C forms, they are not required to amend their tax returns.

If you have any questions or would like assistance in determining if your plan documents comply with the cafeteria plan rules, please contact Eva Rasmussen ( or Richard Muser (, lead attorneys at CB&D's Employee Benefits, Executive Compensation and ERISA Litigation Group.

About the Author
Eva A. Rasmussen
Benefits Counsel
Eva A. Rasmussen concentrates on the design, implementation and communication of qualified plans and deferred compensation arrangements as well as...
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