ARTICLE
5 December 2019

Extension Of ACA Reporting Deadlines And Additional Relief

KR
Kutak Rock LLP

Contributor

Kutak Rock is a national law firm with over 550 attorneys across the U.S., built on a foundation of teamwork, innovation, and exceptional client service. Originally focused on finance, the firm has evolved into a leading provider of legal services in business and corporate law, public finance, litigation, and real estate. Emphasizing collaboration across offices, Kutak Rock delivers integrated legal solutions to business and governmental clients. The firm is committed to long-term sustainability, attorney engagement, and community impact through significant pro bono work. It also prioritizes keeping clients informed with timely legal insights and updates.

The Internal Revenue Service issued guidance yesterday that extends the due date for providing certain Affordable Care Act forms for the 2019 calendar year.
United States Employment and HR

The Internal Revenue Service issued guidance yesterday that extends the due date for providing certain Affordable Care Act forms for the 2019 calendar year. The guidance also eases reporting obligations.

The deadline for sending 2019 Forms 1095-B and 1095-C to individuals is now March 2, 2020 (it was January 31, 2020). However, the IRS will not assess a penalty for failing to furnish 2019 Forms 1095-B if two conditions are met. First, the reporting entity must post a prominent notice on its website that individuals may receive a copy of their Form 1095-B upon request. The notice should include a telephone number and an e-mail address and physical address to which requests may be sent. Second, the reporting entity must actually furnish a 2019 Form 1095-B within 30 days of receiving a request.

The IRS confirmed that penalties will continue to be assessed for failures to furnish 2019 Forms 1095-C to full-time employees. However, penalties will not be assessed in connection with failing to furnish Forms 1095-C to employees who were not full-time employees for any month in 2019 (i.e., employees who were part-time throughout 2019).

The guidance did not extend the due date for filing 2019 Forms 1094-B, 1095-B, 1094-C or 1095-C with the IRS or affect the assessment of penalties associated with these filings.

If you have contracted with a third-party vendor to assist with ACA reporting, we recommend discussing the deadline extension with the service provider and determining whether the Forms will be filed using the original or extended deadlines. The contract or statement of work may need to be amended to reflect any changes to the reporting obligations and deadlines.

If you have any questions or we can be of assistance, please let us know.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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