Tuesday, January 2, 2018

New Deadline for Furnishing Form 1095-C to Employees

1095–C Filing Requirements

Under Section 6056 of the Affordable Care Act, Applicable Large Employers (ALEs) must file information returns with the IRS and furnish statements to full-time employees . Forms are due in the year after the calendar year to which the forms relate. 

IRS Announces Extension of Deadline to Furnish Form 1095-C to Employees

On Dec. 22, 2017, the Internal Revenue Service (IRS) issued Notice 2018-06 which extended the deadline to furnish Forms 1095-C and 1095-B to full-time employees and covered individuals by thirty days. The deadline for furnishing these Forms is now March 2, 2018.  This Notice also extended good faith transition relief for reporting penalties for employers that make a good faith and timely effort to report. 

Notice 2018-06 does not extend the due date for filing forms with the IRS for 2017 and those dates remain February 28, 2018 or April 2, 2018, if filing electronically.  

An ALE may face penalties if it fails to satisfy its Section 6056 reporting obligations. 
These penalties are separate from the ACA’s employer shared responsibility penalties.

For returns required to be filed in 2016 and later, the base penalty amounts under 
Sections 6721 and 6722 were increased. In addition, these amounts are indexed to 
increase with inflation each year. The adjusted penalty amounts are as follows:

Remember, for those employers that use the W-2 safe harbor for affordability, you will need to know an employee’s 2017 W-2 box 1 compensation in order to complete Form 1095-C for that employee.