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Deadlines Loom for ACA Reporting in 2020

Accounting Support • Jan 04, 2021
On December 2, the IRS extended the deadlines for submitting 1095-C or 1095-B forms from 31 Jan to March 2. The transition relief for ACA's "good faith effort" for the year

On December 2, the IRS extended the deadlines for submitting 1095-C or 1095-B forms from 31 Jan to March 2. The transition relief for ACA's "good faith effort" for the year 2019 is also extended.

IRS grants additional reliefs to employers and lets small employers post on their website that Form 1095-B is available on request. The large self-insured employers also have similar grants related to Form 1095-C

Filing Deadlines

ACA Requirement Deadline
1095 forms distribution to employees January 31 (extended to March 2)*
Paper filing with IRS February 28
Electronic filing with IRS March 31

The IRS has extended the deadline for 30 days from Jan. 31. The employers can distribute the 1095-C forms to employees in January with employees' W-2 earnings statements. The IRS will not further extend the 30-days extension or respond to extension requests according to compliance firm Hub International. However, the reporting entities can request individual extensions to file forms with the IRS. But the IRS still encourages employers to send forms to individuals as soon as possible.

Forms and Instructions

The employers should make sure to provide the 1095 reporting forms, except as mentioned below, and transmit the copies. The instructions and the following forms are available on the IRS website:

  • Form 1095-B, Health Coverage.
  • Transmittal Form 1094-B along with Form 1095-B.
  • Instructions for Form 1095-B and Form 1094-B.
  • Form 1095-C, Employer-Provided Health Insurance Coverage.
  • Transmittal Form 1094-C to convoy Form 1095-C.
  • Guidelines for Form 1094-C and Form 1095-C.

Good-Faith Reporting Relief Extended

In IRS notice 209-63, the good-faith relief for reporting has also extended for another year. It is a relief from penalties to employers that report incomplete or inaccurate forms. It includes relief for missing and inaccurate taxpayers, identification number, date of birth, and other information. This relief does not apply to forms filed with IRS or furnished to individuals.

The IRS also takes into account the efforts of employers in gathering and transmitting data to the agent. The employers that fail to furnish forms to employees or file information are not eligible for the relief.

1095-B Furnishing Relief

For 2019 plan reporting, IRS grants additional reporting reliefs to employers providing 1095-B Forms to their employees. If the employers fail to furnish Form 1095-B to workers under the following conditions, they would not be subjected to penalties. 

  1. If they post a notice on their website stating that employees can receive their Form 1095-B upon request. 
  2. If the employers furnish form 1095-B within 30 days of receiving the request.

1095-C Furnishing Relief

According to Fensholt, “the self-insured employers don't need to send a 1095-C Form copy to any employee who was not a full-time employee for at least one month. It means employees that were not full-time employers for the entire 2019 calendar year. Self-insured employers can avail of this relief by satisfying the same notice and furnishing on request requirements. This relief, however, doesn't extend the requirements for furnishing the 1095-C Form to full-time employees.

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