Last Friday, November 18, the IRS published Notice 2016-70, indicating the due date for individual Form 1095 reporting has been extended by 30 days - from January 31, 2017 to March 2, 2017. The notice also extends to the 2016 reporting year the good-faith penalty relief that was in place for the 2015 reporting year.
This notice does not extend the deadlines for filing these forms (and the 1094 transmittal forms) with the IRS; those deadlines are still February 28, 2017 for paper returns and March 31, 2017, if filing electronically.
What this Means for You
- ALL Employers: Employees who enrolled in your group health plan can expect a delay in receiving form 1095-B from insurance carriers, with individual and dependent enrollment info for 2016*
- Large Employers: You have 30 additional days to provide all full-time employees with a form 1095-C, detailing offer of coverage information for 2016
* Notice 2016-70 also provides guidance to individuals who might not receive a Form 1095-B or Form 1095-C by the time they file their 2016 tax returns. Individuals who rely upon other information received from employers or health plans need not amend their tax returns once they receive their forms. In any case, individuals should not attach any 1095 form to their tax returns and should instead keep it with their tax records.
Thank you for your attention to this important compliance E-Alert. Please do not hesitate to reach out to our Group Benefits team with any questions or concerns.