Reporting Deadlines Right Around the Corner

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Internal Revenue Code (IRC) section 6056 requires each Applicable Large Employer (ALE) subject to the Employer Mandate to file information returns with the Internal Revenue Service (IRS) and provide statements to their full-time employees about the employer-sponsored health coverage offered.  This reporting will assist the IRS with enforcing the Employer Mandate and with administering the premium tax credits.  ALEs sponsoring self-insured group health plans are also required to report under IRC section 6055 on everyone enrolled in their self-insured plans.  This reporting will assist the IRS with enforcing the Individual Mandate.

ALEs must report under section 6056 using IRS Forms 1094-C and 1095-C, Parts I and II.  ALEs offering self-insured plans must also complete Part III on Form 1095-C for everyone enrolled in those plans.  Carriers are responsible for the section 6055 reporting for fully-insured plans.

Last November, the IRS extended the deadline for furnishing Form 1095-C to employees to March 2, 2017.  No extensions beyond March 2nd will be granted for furnishing statements to employees.

The deadline for filing with the IRS has not been extended.  These deadlines remain February 28, 2017, if not filing electronically, or March 31, 2017, if filing electronically.  ALEs filing 250 or more forms are required to file electronically.  Requests for an automatic 30-day extension can be made by submitting Form 8809 on or before the filing due date.  No signature or explanation is required for the extension request.  Additional 30-day extensions may be available if extenuating circumstances prevented filing by the due date.