Although IRS officials had been informally saying that the IRS did not have any plans to extend ACA reporting deadlines, the IRS announced right before Christmas that it was granting employers an automatic extension of the deadline to distribute 2017 1095-C forms to employees. IRS Notice 2018-16 extends the distribution deadline from January 31, 2018, to March 2, 2018. No additional extensions will be granted. However, the deadline for filing the 1095-C forms with the IRS, along with a 1094-C form, remains February 28, 2018, if filing by paper, and April 2, 2018, if filing electronically.
This extension applies primarily to employers who averaged 50 or more full-time equivalent employees during the 2016 calendar year. But, smaller employers with self-insured health plans that distribute 1095-B forms to participating employees are also entitled to this extension.
The IRS has also extended its good faith transition relief to the 2017 forms. Under this relief, the IRS will not penalize an employer if it turns out that the information on the employer’s forms were inaccurate or incomplete, so long as the employer had distributed and filed the ACA forms on time and can demonstrate that it made a good-faith effort to comply with the ACA’s information reporting requirements. This is welcome news—especially since the IRS is only now starting to highlight reporting errors as it begins to send out its first ACA penalty assessment notices for 2015.
If you need any assistance with ACA reporting or have other questions about ACA compliance, please contact Norbert Kugele, Stephanie Grant, Kent Sparks or any other member of the Warner Norcross + Judd Employee Benefits Practice Group.
