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Approaching Deadlines for Affordable Care Act Reporting

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As we recently reported in our “2017 End of the Year Plan Sponsor To Do List,” applicable large employers must continue to submit to the IRS and to employees information regarding offers of health coverage made to full-time employees in 2017.

The IRS recently published Notice 2018-06 (the “Notice”), which contains some relief with respect to the required reporting.  In particular, the Notice extends the deadline to distribute Forms 1095-C to employees and continues the application of good faith transition relief.  The Notice does not extend the deadline for filing Forms 1094-C or 1095-C with the IRS.

Extension of Deadline to Furnish Forms 1095-C to Employees

The Notice extends the deadline for furnishing Forms 1095-C to employees from January 31, 2018 to March 2, 2018

It is important to note that the Notice does not extend the deadline for filing Forms 1094-C or 1095-C with the IRS.  The deadline to file those Forms remains February 28, 2018 (for paper filings) or April 2, 2018 (for electronic filings).  Note that the traditional electronic filing deadline of March 31 falls on a weekend and has been moved to the next following business day, April 2, 2018.

Extension of Good Faith Reporting Relief

The Notice also extends good faith transition relief for calendar year 2017 reporting.  The IRS provided similar relief with respect to 2015 and 2016 reporting.  As in prior years, employers who submit incorrect or incomplete Forms may be relieved from penalties if they can show that they made good-faith efforts to comply with the reporting requirements.