Q.- Our plan year starts July 1. Does our non-calendar year plan impact the timing by which we must distribute Form 1095-C and transmit Form 1094-C?
A.- Your plan year does not impact the due date for Forms 1095-C or Form 1094-C. Health care reform reporting is on a calendar year basis. Form 1095-C must be distributed by January 31 of the year following the calendar year to which the return relates. Form 1094-C must be transmitted by February 28 if filing on paper (or March 31 if filing electronically) of the year following the calendar year to which the return relates.