The IRS has announced a welcome extension of the 2020 due date for certain entities to provide 2019 health coverage information Forms 1095-B or 1095-C to employees and individuals. Limited penalty relief is also extended to the 2019 Forms. Visit this IRS webpage for information on the health coverage forms requirement.
Due Date Extended to Issue Forms to Employees/Individuals
Insurers, self-insuring employers, other coverage providers, and applicable large employers (ALEs) now have until March 2, 2020, to provide Forms 1095-B or 1095-C to employees and individuals. The IRS has announced that further extensions beyond this new due date will not be available and the IRS will not be formally responding to extensions that have already been requested by reporting entities. The extension for filing Forms 1095-B or 1095-C to individuals is automatic. Employers and providers don’t have to request it. The IRS will not grant an additional 30-day extension beyond this deadline.
Due Date NOT Extended for Forms to IRS
The due dates for filing Forms 1094-B, 1095-B, 1094-C or 1095-C with the IRS are not extended. Therefore, employers filing by paper must submit their Forms to the IRS by February 28, 2020. Those filing electronically have until March 31, 2020. As a reminder, employers and coverage providers who are filing more than 250 of these reporting forms are required to file electronically.
Special Note on State Employer Reporting Requirements
Note that insurers and employers in certain states (e.g., Massachusetts, New Jersey and Washington, D.C.) that have enacted individual mandates are required to file the 2019 Forms 1094-B, 1095-B, 1094-C or 1095-C with the state and furnish the Forms to state residents. More Information on state-level individual mandates available.
Good Faith Penalty Relief
Finally, the announcement extends the program for the IRS granting good faith relief for certain errors. Employers and coverage providers who work in good faith to complete the returns or statements will not be assessed penalties due to missing or inaccurate information. This relief applies only to missing and inaccurate information required on the Forms and does not provide relief in the case of reporting entities that do not make a good-faith effort to comply with the regulations or that fail to file an information return or furnish a statement by the due dates.
We will continue to monitor developments under the Affordable Care Act and provide details on new and revised employer obligations as they take shape over time.
