In a move sure to add more complexity and uncertainty to an already complex and uncertain Affordable Care Act compliance situation, the Internal Revenue Service on December 28 announced extensions of the 2016 ACA information reporting deadlines.

Specifically, IRS Notice 2016-4 extends the due dates for Code section 6055 information reporting by insurers, self-insured employers and other providers, and for Code section 6056 information reporting by applicable large employers as follows...  

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Breaking News: ACA Reporting Due Dates Extended

Tue Dec 29, 2015

In a move sure to add more complexity and uncertainty to an already complex and uncertain Affordable Care Act compliance situation, the Internal Revenue Service on December 28 announced extensions of the 2016 ACA information reporting deadlines.

Specifically, IRS Notice 2016-4 extends the due dates for Code section 6055 information reporting by insurers, self-insured employers and other providers, and for Code section 6056 information reporting by applicable large employers as follows:

  • The due date to furnish individuals the 2015 Form 1095-B and the 2015 Form 1095-C is extended from February 1, 2016 to March 31, 2016.
  • The due date to file with the IRS the 2015 Form 1094-B, the Form 1095-B, the Form 1094-C and the Form 1095-C (Employer-provided Health Insurance Offer and Coverage) is extended from February 29, 2016 to May 31, 2016 and, for electronic filers, to June 30, 2016.

Code section 6056 Form 1095-C reporting is of particular concern to employers because it is to be used to provide employees and the IRS information about health coverage offered to full-time employees and their dependents.

Form 1095-C contemplates the use of certain “Indicator Codes” to report, on behalf of individual employees, monthly offers of “minimum essential coverage,” monthly premiums for lowest-cost, self-only coverage and various employer “safe harbors” related to potential employer penalties.

Code section 6055 requires health insurance issuers and self-insured employers to file and furnish annual information returns and statements regarding coverage provided.

The IRS announcement, ostensibly because “some employers need additional time…to gather, analyze and report this information,” is tacit acknowledgement that the original reporting requirements may simply be too complex for too many employers.

The big question is, what happens next? Can the problem really be solved by extending the due dates a few months? Or is the more fundamental problem the regulations themselves—or worse, the Affordable Care Act itself?

Perhaps the regulations can be streamlined in the next few months to make employer reporting of health coverage information easier. Or perhaps Congress on a bipartisan basis should correct the statutory language that created what is clearly an overly complex reporting mandate.