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Client Alert: IRS Extends Deadline for ACA Information Reporting

The Internal Revenue Service (“IRS”) has just extended the deadline for Information Reporting under Internal Revenue Code sections 6055 and 6056 by two to three months. IRS Notice 2016-4 extends the due dates for the 2015 information reporting requirements under […]


The Internal Revenue ServicFB - FinalTreee (“IRS”) has just extended the deadline for Information Reporting under Internal Revenue Code sections 6055 and 6056 by two to three months.

IRS Notice 2016-4 extends the due dates for the 2015 information reporting requirements under both Internal Revenue Code (“Code”) sections as follows:

  • Section 6055 for insurers, self-insuring employers, and certain other providers of minimum essential coverage; and
  • Section 6056 for applicable large employers.

The extension applies with regard to furnishing statements to individuals, as well as filing with the IRS.

Specifically, IRS Notice 2016-4 extends the due dates as follows:

  • For furnishing to individuals, the deadline is now March 31, 2016 (extended from February 1, 2016), affecting:
    • 2015 Form 1095-B, Health Coverage, and
    • 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage
  • For paper filings with the IRS, the deadline is now May 31, 2016 (extended from February 29, 2016), affecting:
    • 2015 Form 1094-B, Transmittal of Health Coverage Information Returns,
    • 2015 Form 1095-B, Health Coverage,
    • 2015 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and
    • 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage.
  • For electronic filings with the IRS, the deadline is now June 30, 2016 (extended from March 31, 2016), also affecting:
    • 2015 Form 1094-B, Transmittal of Health Coverage Information Returns,
    • 2015 Form 1095-B, Health Coverage,
    • 2015 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and
    • 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage.

You can find the full Notice at this LINK.

For background and additional information regarding the ACA Information Reporting Requirements, please see our previous Client Alert from September 18, 2015 at this LINK.

This alert just serves as a general summary of the lengthy and comprehensive Information Reporting instructions and forms. For more information on this issue, please contact Fraser Trebilcock attorney Elizabeth H. Latchana at 517.377.0826 or elatchana@fraserlawfirm.com.