SPECIAL ALERT- Health Care Reform (ACA) Reporting Delayed

Posted by BAS - 12 January, 2016


As a last-minute holiday gift, the IRS has extended the due dates for Affordable Care Act (ACA) information reporting. The extension applies to the 1095-B/C Notice sent to individuals and to the 1094- B/C Transmittal to the IRS. 

The new timeframes are as follows:

  • Reporting to Employees.  Form 1095-B and Form 1095-C must be provided to employees/covered individuals by March 31, 2016 (changed from February 1, 2016)
  • Reporting to IRS.  Form 1094-B and Form 1094-C must be transmitted to the IRS by May 31, 2016 if filing by paper, or by June 30, 2016 if filing electronically (changed from February 29, 2016 and March 31, 2016)


Sections 6055 and 6056 were added to the Internal Revenue Code by the Affordable Care Act.  Section 6056 requires an applicable large employer to provide information about the coverage it offers or does not offer to its full-time and full-time equivalent employees.  Section 6055 requires an employer of a self-funded health plan, a health insurance issuer and any other provider of minimum essential coverage to file and provide annual information returns and statements about the coverage it provides.  This reporting is accomplished through Forms 1095-B/C and Form 1094-B/C. 

The Code imposes penalties for failing to file or filing an incomplete return and failing to provide or providing an incorrect information statement. 

Transition Relief

The IRS determined that some employers needed additional time to implement reporting systems and to gather the data required to report properly. With the new deadlines, the IRS observed that it will not accept any additional time extension requests past the revised due dates. 

The IRS will accept 2015 reporting as early as January 2016. 

A copy of Notice 2016-4 implementing the filing delays can be accessed by clicking here.  

If you have questions about the extended filing due dates or about BAS' MyEnroll Health Care Reform Data Collection and Reporting capabilities, please contact your account manager or solutions@BASusa.com.

 Note: For our current ACA clients, over the next few days, we will develop a revised data approval and 1095B/C forms production schedule. You can expect to receive the revised schedule next week.

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