As previously reported, the Internal Revenue Service (“IRS”) extended the deadline for Information Reporting under Internal Revenue Code sections 6055 and 6056 by two to three months. However, paper filing dates have now passed; and electronic filings are due by June 30^th.

Information reporting requirements are applicable 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.

Specifically, the deadline for filing electronically with the IRS is June 30, 2016 (extended from March 31, 2016), which involves:

• 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.

The due date for furnishing to individuals was 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

The deadline for paper filings with the IRS was 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.

You can also find the IRS Reminder HERE.

For background and additional information regarding the ACA Information Reporting Requirements, please see the Client Alerts previously provided on September 18, 2015 and December 28, 2015.

Accurate reporting by employers is a key to compliance. The IRS is actively encouraging employers to file accurate returns. Do not ignore missed deadlines or inaccurate filings. Correction mechanisms have been put in place by the IRS. Work diligently to fix any known issues. As always, we are here to assist with any of your employer reporting needs.

This alert just serves as a general summary of the lengthy and comprehensive Information Reporting instructions and forms.

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Elizabeth H. Latchana specializes in employee health and welfare benefits. Recognized for her outstanding legal work, in both 2018 and 2015, Beth was selected as “Lawyer of the Year” in Lansing for Employee Benefits (ERISA) Law by Best Lawyers, and in 2017 as one of the Top 30 “Women in the Law” by Michigan Lawyers Weekly. Contact her for more information on this reminder or other matters at 517.377.0826 or elatchana@fraserlawfirm.com.