On 12/28/2015 the IRS announced that it is extending the distribution and filing deadlines for the new 1094/1095 forms tied to ACA compliance, as follows:
- The delivery deadline for 1095 forms, which were to be provided to eligible form recipients on or by February 1, 2016, has now been extended to March 31, 2016.
- The filing deadline for the 1094 form, which was to be manually filed on or by February 29, 2016 has now been extended to May 31, 2016. The deadline for electronic filing has now been extended from March 31, 2016 to June 30, 2016.
There are several important observations and recommendations we wish to share in the wake of this news:
- Employers should check with their ACA filing partners to determine if the resulting deadline changes will in any way alter the timeline for processing and delivering the 1095 forms to be provided. The expectation is that they will not, meaning the 1095 forms for your eligible recipients / employees will still be provided on or around February 1, 2016.
- If your firm chooses to take advantage of the extended filing deadline and therefore deliver your 1095 forms after February 1, 2016, it is advised that you inform your employees slated to receive such forms of said delay. THE KEY ISSUE – some recipients of 1095 forms will not be able to file their 2015 tax return without the form in hand, unless the employer provides interim guidance as to how to answer questions on their tax forms about the coverage they received. As such, this may delay the ability for some to file, and in some cases, more rapidly collect a tax refund.
If you have any questions pertaining to ACA compliance or related services, please know that the OperationsInc team is here to help and offer expert advice, filing services, and consultation.
Click HERE for the full IRS announcement.